ML19347C666
| ML19347C666 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/31/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19347C658 | List: |
| References | |
| NUREG-0752, NUREG-752, NUDOCS 8101050063 | |
| Download: ML19347C666 (30) | |
Text
..
e NUREG-0752 Contro Room Desicn Review Recor:
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for TVll-1 Metropolitan Edison Company, et el.
Three Mile Island Nuclear Station Unit 1 Docket 50-289 U.S. Nuclear Regulatory Commission office of Nuclear Reactor Regulation l
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Contro loom Design Review 9eaort "or - V l-1 Metropolitan Edison Company, et al.
Three Mile Island Nuclear Station Unit 1 Docket 50-289 Manuscrict Comp!eted: December 1980 Date Published: December 1980 Division of Human Factors Safety Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 lW
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ABSTRACT Based on our human factors engineering review and evaluation of the TMI-l 4
control room, we conclude that correction of the deficiencies herein identified and discussed prior to restart will pemit safe operation of the TMI Unit i nuclear plant. Prior to restart, we will arrange to audit
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the control room to ensure all human factors engineering improvements are imolemented.
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t TABLE OF CONTENTS i
9 Pace
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A.
Introduction...............................................
1 j
B.
Positive Design Factors Observed During the NRC Control j
Room Design Review.......................................
2 C.
Deficiencies Identified In The Control Room Design Review..
3 Deficiencies to be Corrected Prior to Restart..............
5 1.
A n nu nc i a to r s a nd Al a rm s...............................
5 2.
Process Computer......................................
5 3.
Co nt rol s ( G ene ral )................................ '...
7 4
D i s pl ay s (G enera l )....................................
9 5.
Labeling (General)....................................
11 6.0 Control Disp!ay Relationship.........................
12 6.1 General........................................
12 v keup and Purification System.................
13 6.2 a
6.3 HVAC System....................................
15 7.0 So u nd L ev el s.........................................
15 8.0 O t h e r O b s erv a t i o n s...................................
16 9.0 R emote Shutdown P a nel (RSP )..........................
17 10.0 Communications In The Control Room...................
18 11.0 Operator Emergency Equipment.........................
19 12.0 Eme rg e n cy P ro c ed u r e s.................................
20 13.0 Lighting.............................................
20 14.0 General Connents.....................................
21 D.
Conclusions................................................
22 Appendix I.................................................
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HUMAN FACTORS ENGINEERING BRANCH CONTP.0L R00ft nESIGN REVIEW (CRDR) REVIEW TMI, UNIT 1 A.
INTRODUCTION In our letter of November 25, 1980 to Met-Ed (D. G. Eisenhut to R. C. Arnold), we documented certain requirements of NUREG-0694, "TMI-
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Related Requirements for New Operating Licenses", which we believed should be completed prior to restart of Tiil-1. Among th'ese is Item I.D.1, control Room Design. As part of this requirement, members of the staff and a human factors consultant conducted a human factors review of the THI-1 control room design from July 21 to July 25, 1980.
This report presents the results of that review.
On the morning of July 21, 1980, we were given about a two hour presentation by Met-Ed's human factors consultants. They discussed preliminary findings of their control room assessment which had been underway several months prior to our CRDR visit. Many of the human factors design deficiencies noted during our design review were identified and discussed by Met-Ed's human factors consultants. The staff's CROR included an evaluation of control room layout, the adequacy of the infomation provided, the arrangement and identification of important controls and instrumentation displays, the usefulness of the audio and i
visual alarm systems, the infomation recording and recall capability, lighting, and other considerations of human factors that have an impact on operator effectiveness. This review was performed by means of de-a tailed insoection of the control panels, interviews with operators,
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t and observation and videotaping of operators as they walked through selected emercency procedures. A number of the human factors design deficiencies noted during the NRC review, and identified by Met-Ed's human factors cor.sultants, were in the process of being corrected at the time of our review.
On October 10, 1980, the NRC staff met with the licensee at the office of their human factors consultant, MPR Associates. They and their con-sultant made a presentation on the status of their ongoing control room design review, and also discussed the NRC control room design review report transmitted to the licensee on September 16,1980 (Appendix I).
The licensee was not prepared to discuss the actions they would take to correct the deficiencies identified in the September 16th NRC report.
The licensee stated that its response to the NRC report would be forth-m ing within two weeks. On October 27th, we received a copy of the licensee's draft response to our September 16, 1980 report. The licensee's final response was received on November 7, 1980, and addi-tional discussions were held witn the liccnsee through early December, 1980.
B.
POSITIVE DESIGN FACTORS OBSERVED DURING THE NRC CONTROL ROOM DESIGN REVIEW Although our review identified some human factors design deficiencies, in-I' general, we found that the control room was designed to promote effective l
ooerator actions. Some positive design factors are as follows:
In most instances, the annunciator planels are located above systems panels which they monitor.
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, The ambient oackground noise level is low.
Left to right and top to bottom organization of controls and displays are generally consistent with plant and stereotypical convention.
The nomal lighting of the main control console is good.
The control panels are generally not overcrowded with controls and displays.
Switches on the SS-1 panel are all guarded against inadvertent actuation.
The process computer alarn will sound until an operator acknokledges the alam.
~ e alam and utility printers provide clear legible oisplays.
C.
DEFICIENCIES IDENTIFIED IN THE CONTROL ROCM DESIGN REVIEW The review team identified a number of human factors deficiencies which w documented in a draft report which was transmitted to the licensee (letter of Sectember 16, 1980, to "r.
R. C. Arnold from Mr. Robert W. Reid). The draft
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l report categorized the deficiencies as to their importance.
On October 10, l
1980, a meeting was held with the ifcensee and his consultant to discuss the draft report.
The licensee raised concerns about the staff's scheme for categorizing the imoortance of control room deficiencies.
We agreed to L
consider the licensee's concerns regarding the categorization scheme.
l The draft report categorized the deficiencies as follows:
l 1.
Serious Concern - Human / System perfomance degradation with serious cotential safety consequence.
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. i w derate Concern - Human / System cerfonnance degradation with moderate 2.
o ij potential safety consecuence.
'h 3.
Other Concerns - These require an evaluation by the licensee for future resolution.
l The licensee questioned the categories in that the level of concern was based only on the consequence of hu an error and not on both the potential for human error and the consecuence.
In categorizing the deficiencies we r-L did consider both the potential for error and the consequence of the error, however, we agree that the category definition given in the draft recort did not clearly state the categories actually used. We concluded that the TMI-l deficiencies had been properly categorized but the following more clearly described the categories:
Observed human factor design deficiencies were given a priority rating of one to three, (high, moderate, low), based on the increased potential for operator error and the possible consequences of that error.
The licensee transmitted its response to the staff's Septenber 16th draf t E
report on November 7,1980. The staff considered the licensee's response l
in its safety evaluation and in arriving at the corrective neasures required.
The required corrections of control room deficiencies are discussed i
l below. We require correction of most of these deficiencies prior to restart. The schedule for recuired corrections pennitted later than restart is indicated.
i Some deficiencies will need further analysis to arrive at permanent or ootimum solutions. We will require the licensee to comit to address these deficiencies as part of their detailed control rocin design reviev required by item I.D.1, and will expect final resolution of these deficiencies on a schedule to be proposed by the license as part of the detailed review. The nature of these deficiencies or temporary solutions that are required before restart are such that they present 1
no significant safety risk that would preclude restart and full twer operation.
In addition to any deficiencies the licensee may identify as a result of its detailed control room design review the licensee will be required to address the deficiencies identified in the staff's draft report as category 3 items.
Category 3 items have been omitted from this report, however, they will be discussed and reported on in the licensee's detailed control room design review report which will be completed in accordance with tre provisions of NUREG-0737.
Items 6.k and ll.b of the September 16th draft report (Appendix I) have been omitted from this report as a result of clarification of 6.k by the licensee, and because ll.b is being covered in the procedures review.
Items concerned with the shift supervisors office (10.a and 10.b) and the technical support center (13.a and 13.b) are not addressed in our report because of their dated requirements and the fact that construction of these areas is not far enough along for us to evaluate.
l Deficiencies to be Corrected Prior to Restart In the list of deficiencies to be corrected prior to restart whicn follows, paragraoh numbers which are not comoarable to the numbers used in the Sectember 16, 1980 staff recort are icentified.
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6 1
Annunciators and Alarms a.
TFe licensee's system lacks a separate acknowledge / silence control and permits operators to acknowledge alarms without reading alarm windows.
The licensee is evaluating an alarm system with a separate acknowledge and silence control which would permit saving the flashing tiles (last alarm received) for diagnostic purposes.
The evaluatio. and final resolution of the alarm system de.
ficiencies will be addressed in the licensee's detailed control room design review report for NRC review and aoproval.
In the interim, the licensee will ensure that alarms are not acknowledged until operators have reviewed and understood the significance of each alarm and flashing tile. This will be accomplished either by administrative procedure or operating crocedure.
b.
There is minimal annunciator prioritization. Some blue markings on ESAF alarm tiles are not readily identifiable.
The licensee will review each alarm for importance and the response required for each. The window tiles for the important safety alarms will be color coded.
In addition, the tiles associated with the Engineered Safeguards Actuation System (ESAS) which have blue colored corners will be improved to aid operators I
I by decreasing the search time necessary to identify such window tiles.
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4 1 l Some annunciator tiles have busy legends.
c.
Safety significant window tiles with crowded legends and small print font will be replaced.
2.
Process Computer The CRT display was of coor quality and could increase the a.
pratability of reading error.
A new CRT display system will be installed in the control room.
b.
The process computer capability is limited and its vintage raises the ouestion of reliability of information presented to operators.
A new printer capable of providing more current information will be installed.
In addition a new process computer will also be installed. The new computer will not be fully operational prior to restart, however, some functions, which will back up feactures of the original computer, are expected to be operational.
3.
Controls (General)
A number of controls (J handle, etc.) located near the front a.
edge of the operating console could be inadvertently activated.
A guard rail or an alternative means will be provided to protect against inadvertent actuation of "J" handle or other i
j switches located near;the front edge of the control console.
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- b.
Set point knobs en Bailey controllers do not cc', and can be accidently rotated.
The licensee will emphasize during operator training and retraining the need to frequently check controller set point knob settings. Final resolution of this deficiency will be addressed in the Li 'asee's DCRDR report.
c.
Plant convention is violated for auto / manual positions on some multiple position rotary controls (Sync. Scope and Voltage Regul ator).
The licensee will implement an improved labeling program which will concensate for problems associated with violation of con-vention concerning multiple position rotary controls.
d.
Legend switch covers are interchangeable.
The licensee will imolement a program either through administrative or coerating procedures, to lessen the possibility of interchanging switch covers. Fir.al resolution of this ceficiency will be addressed in the Licensee's DCRDR report.
e.
Legend indicators contain numerous burned out bulbs.
A fomal surveillance program will be implemented to detect and replace burned out indicator lamps for panels which do not have a lamp test capability. Final resolution of this deficiency will be addressed in the Licensee's DCRDR report.
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'*any filuminated legend switches are difficult to read.
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Inproved labeling will be installed which will lessen the coerator's dependence on information contained on illuninated legends. Illuminated legends important to safety, which are difficult to read, will be. replaced, i
g.
Bailey controllers indicate demand signal rather than valve position (3.h)*
The licensee will emphasize during ooerator training and retraining that controller indicators display the controller demand signal, rather than actual valve position.
In addition, the licensee will improve labeling of the controllers, the meter selector switches, and certain controller meter sca7es.
Final resolution of this deficiency will be addressed in the Licensee's DCRDR report.
Emergency feedwater flowmeters will be installed in the inmediate vicinity of the controllers, and, near backup manual controllers, which will be added.
- Qefereaces are to tne HFIB Report transnitted to the licensee en September 16, 1980.
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Disciays (General)
Panel legend lights do not provide positive status indication because of coor contrast with panel background.
Panel legend lights will be adjusted and replaced to provide consistency of illumination and improve contrast with the panel tackground.
If necessary, certain green colored tiles will also be replaced to improve c::ntrast.
2.
Glare is present on all vertical indicators resulting in redachd readability.
Light baffles or other means will be used to reduce light glare on vertical ceters.
In addition, new label plates which are not affected by glare will be installed.
c.
Nomal operating ranges or set peints are not indicated on vertical meters.
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Nomal operating ranges or set points will be indicated on meters which have safety significance, where nomal range / set point infomation can be identified.
d.
Most meters fail at mid-scale position (4.e)*.
A system of annunciators and indicators to signal upsets in the power supplies to the ICS and NNI control systems will be installed.
In addition, a distinctive mark to identify the l
mid-scale point will be placed on instruments to assist operators l
in identifying instrument failures.
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- 11 For some motor driven valves, an open circuit breaker inhibits e.
valve position indication because indicators are pcwered fecm the bus that he breaker drops (4.f)*.
3 second independently powered position indication circuit is provided for certain valves to show valve position after the circuit breaker for a particular motor driven valve is tripped.
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Backlighted legends are difficult to read. Room lighting is dim, contrast is mir.icci, lettering is crowded and busy and dis-coloration on scratched surfaces is frequent (4.h)*
Same requiremenc as for Item 3.f.
g.
No lamp test capability on control boards or panels.
(4.i)*
Same reoufrement as for Item 3.e.
5.
Labeling (General) l a.
Color 2 3nint is not consister.t.
The licensee will utilize color codes which are consistent.
b.
In general, labels are used only at the component level, not at the group,-function, system, or panel level.
(5.c)*
l The licensee will provide for a hierarchial scheme of labeling.
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c.
The use of color labels is not consistent, for example, black /
white background and print.
(5.d)*
Same requirement as for item 5.a.
d.
Makeshift labeling was observed on many components including penciled on switch nomenclature, hand lettered labels and vertical meter scale values and the use of dymo tape.
(5.e)*
Makeshif t labels will be reolaced with permanent label plates with consistent color coding and letter size.
Labels are not all permanently attached.
(5.f)*
e.
All labels will be oermanently attached.
f.
Little or no use of denarcation lines to separate systems, subsystems, functional grouping, etc.
(5.g)*
Denarcation will be added to panels to separate controls /
displays by system, subsystem and functional grouping, Labels are wordy, because the function of a system is repeated g.
on each switch of a group.
(5.h)*
Implementation of a hierarchial system of labeling as noted in 5.a and improved labeling will provide operators with clear readable labels.
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6.0 CONTROL DISPLAY RELATIONSHIP i
6.1 General Related controls and displays do not consistently have both nemenclature and comconent designation.
The licensee will assure that related controls and displays will be consistently labeled.
6.2
'takeup and Purificatica System:
a.
Makup pumps are not grouped together.
The licensee will assure through effective labeling and demarcation that the relationships between the two control / display segments are clearly distinguishable.
l b.
Lacks positive indication of flow when makeup pump is running in the make-up mode.
Individual makeup oumo flow indication is not provided, however, an indication of total makup pumo flow is provided.
The licensee will assure through training and retraining that coerators need to observe flow transients when a makeup pump is started.
It is impossible to verify a required reading of 3 spm flow on c.
the'RC Makeup Flow Meter which has Scale Values of 0 to 16 (x 10).
(6.2e)*
f The required reading of 3 gpm, from the makeup system operating procedure, is accomplished locally on a meter which has a scale of 0 to 4 gpm. This will be made clear in the procedure.
d.
Letdown flow meter is in gpm while scale on controller is in percent and must be converted before setting.
(6.29)*
The corversion between flow rate and valve position is not important because the operator will adjust valve position based on the flow meter reading to achieve desired flow rates rather than by adjusting for valve position. Therefore, this is not now considered a deficiency.
e.
There is no Engineered Safeguards / Safety Injection annunciator window.
(6.2h)*
The Engineered Sareguards System activation is currently indicated by a mislabeled alann window. This will be corrected.
f.
Engineered Safeguards Actuation Panel has blue status lights which are difficult to interpret as being "on".
(6.21)*
The ESAF panel blue status lighted windows will be modified to improve brightness and contrast for easier operator identification.
g.
Valve positions (containment isolation) at bottom of Engineered I
Safeguards Actuation Panel cannot be seen from main console.
There appeared to be no color sequence or pattern to help check I
which valves should be opened or closed.
(6.2j)*
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Valve position indications at the bottom of the ESAF panel are repeated on the upper ESAF panel section and therefore are not required to be read by an operator in front of the ocerator's console. The blue / yellow indicator lights used on the >pper panel provide the operator information that is needed to determine whether the Engineered Safeguards positions are achieved. There-fore, this is not now considered a deficiency.
h.
CHR temp ano DHR cooler teno indicators are side by side but I
have different scale multipliers.
(6.21)*
The meter scales for the decay heat removal temperature indicators will be changed to be consistent.
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DH, 5, 6, 7 valve controls are not included in mimic.
(6.2n)*
The decay heat removal system mimic will be completed and the connection between the decay heat and makeup systems will be indicated.
6.3 HVAC System:
a.
No separation or demarcation of grouped J Handle control switches j
(9 in a row).
Grouped controls and displays associated with control room ventilation will be functionally grouped through the use of demarcation lines and new labels. The remainder of the HVAC system labeling and demarcation will be completed on a schedule to be proposed by the licensee as part of the detailed review.
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b.
Labeling does not contain information which incicates time required for depressing and holding manual fan start control to start fan (varies by fan, 30 to 90 sec.).
(6.3d)*
Labels which include the time to depress and hold information for fan start controls will be provided.
7.0 SOUND LEVELS The IBM-Selectric printer is 65 dbA while typing. This level is a.
5 to 6 dbA above ambient and 4 to 5 dbA above most ala m levels.
The process computer printers have been replaced with units which are approximately 8 dbA quieter than the original printers. Therefore, this item is no longer considered a deficiency.
b.
Main control board alarm is below ambient noise level.
Panel Left (PL) alarm is only 1 dbA above ambient noise level.
c.
d.
Right Panel Front (RPF) alarm is only 1 dbA above ambient noise
- level, Liquid Waste System alarm is below the ambient noise level.
e.
The alarm levels for the main control board, panel left, right panel front and the liquid waste system alarms will be adjusted so that they will be from 6 to 10 dbA above the ambient noise.
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3.0 OTHER OBSERVATIONS a.
Diesel Generator Governor has no indication on J handle switch for fast / slow speed control ', a:h is inccasistent with other speed controls.
The yellow indicator lights which indicate " idle" and "high" speeds will be changed to white indicator lights. New labels will be added that will contain the speed control information.
b.
On DHR system, controls for loop A and B were not associated with their displays which are located approximately 8 feet away.
(8.c)*
One DHR indicator and control switch which are part of loop A c.
panel are located on loop B panel.
(8.d)*
Relabeling, color coding and demarcing will be used on the DHR system controls and displays to make their functions and relation-ships clearer to operators.
d.
Discrimination between systems and subsysters is difficult because of lack of use of demarcation lines and color coding.
(8.e)*
Color coding and demarcation lines will be added to aid in dis-criminating between systems, subsystems and functional grouping of controls and displays.
I Auxiliary Feedwater system lacks a flow meter.
(8.f)*
e.
f A flow meter for the auxiliary feedwater system will be installed.
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f.
Control / Display arrangements for the ICS (feedwater, steam level)
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(8.h)*
Improved labeling, color coding and demarcing of the ICS controls and displays will t.e added to improve their relationships.
9.0 RE. MOTE SHUTDOWN PANEL (RSP) a.
The panel is not independent of the Control Room - all actions other than the starting and stopping of RC pumps are required to be nerformed in the centrol room and local areas of the plant.
A newly designed remote shutdown panel and a revised emergency procedure using the new panel for cool down operation independent of the control room will be implemented, b.
Emergency lighting is not prcvided at this panel, i
The remote shutdown panel will be provided with emergency lighting.
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c.
Conmunication from the RSP is by sound powered microphone with no microphone / head set located in the area.
A sound powered microphone / headset will be permanently available at the remote shutdown panel. To provide additional concunica.
tions capability available in the Technical Support Center (TSC),
keys to the TSC will be available in the control room, from the shift supervisor and from the person on duty responsible for the TSC.
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No scott-air packs are provided at the RSP.
Scott air packs will not be needed in the RSP area during emergencies because habitability of the area is assured by the air recirculation system. Therefore, this iten is not considered to be a deficiency.
10.0 CCMMUNICATIr,NS IN THE CONTROL ROOM a.
Sound powered microphones / headsets are not readily available.
(11.5)*
Two sets of sound powered microphones / headsets are kept in the computer cabinet in the control room. This will be emphasized to control rocm operators.
b.
There are weaknesses in the radio connunications system when communicating with a technician outside the CR area.
(11.c)*
The plant paging system will be used for in-plant communications, the two-way radios will not be used. However, the licensee is studying the overal' communications system at TMI-l to determine improvements that can be made and will report on its findings in the detailed control room design review report, expected to be completed by the end of 1982.
There are some inoperable page telephones in the plant area.
c.
Some areas in the plant are not reachable by telephone.
(11.d)*
Inoperable page telephones in the plant area will be repaired.
Areas in the plant that should have paging system telephones will
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be identified and pnones will be installed. The plant paging system will be included in the licensee's study discussed in paragraph 10.b abete.
11.0 OPERATOR E.MERGENCY EOUIPMENT ll.a Three Scott Air Packs are kept in the CR, however, during emergency operations there are eleven people planned to be in the CR.
(12.a)*
Scott Air Packs are not required for operator use in the control room. Habitability of the control room is assured curing emergency conditions by the control room air recirculation system. However, the units kept in the control room will be available for use by operators in the control room if needed.
12.0 EMERGENCY PROCEDURES Immediate 5ction steps in some procedures are too detailed and a.
some require an excessive number of steps to be completed immediately.
(14.a)*
b.
Some immediate action steps which require two operators to imple-ment are not so noted. (14.c)*
Scme procedures, have " notes" which are actually immediate action c.
steps.
(II.d)*
l d.
Some crocedures reference centrol and display labels which have functions different from the functions actually used on the labels.
(14.e)*
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These items will be corrected in the course of the review required by the letter from D. G. Eisenhut to R. C. Arnold, dated November 25, 1980.
Although these items were identified during our control room review, they will be considered in the cour*t of the procedures review required by Item I.C.8 as identified in the letter from D. G. Eisenhut to R. C. Arnold, dated November 25, 1980.
13.0 L'GHTING Normal and emergency lighting was not specifically designed for a.
reading labels, displays and meters, i.e., problens with contrast, glare and illumination levels. (15.a)*
b.
Direct glare from overhead lights on both controls and disniays make readability difficult.
(15.5)*
The licensee's lighting survey indicated that normal control room lighting levels are consistent with recognized standards (MIL-STD-1472B and IES Lighting Handbood). Glare problems associated with normal lighting are discussed in paragraph 4.b.
Emergency lighting levels will be increased where needed and light fixtures will be moved to positions that will assure adequate illumination of controls and displays. Also, light baffles or i
other means will be utilized where necessary to reduce direct l
i glare caused by the emergency lighting system.
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a 22 c.
No lighted exit sign in the control room.
(15.c)*
A lighted exit sign is not needed in the cortrol room because the control room will be illuminated for all anticipated situations.
Therefore, this item is not considered to be a deficiency.
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GENERAL COMMENT
S a.
No formal system exists for providing operators feedback about suggestions made.
(16.a)*
The licensee has a formal system by which operators receive feedback on suggestions made, through the operator's filing of a GPU Preblem Report. Therefore this item is not considered to be a deficiency, b.
Sub-cooling instrumentation is not in place and operating.
(16.b)*
Sub-cocling margin instrumentation and displays will be installed l
and e?erating.
c.
In-core thermocouples (te ) have been connected to the process s
computer, a monitoring program (software) has been written and i
l the system is in the checkout process. The applicant's system contains 52 in-core thermocouples with readout range up to 2300*F.
Thermocouple information will be displayed on the Bailey computer console by use of a CRT, and hard copy printed on demand. A back-up system display with a capability for selective reading of a l
minimum of 16 operable thermocouples, 4 from each quadrant, all within a time interval no greater than 6 minutes, powered from a power source independent of the process canputer/CP.Ts will be required prior to restart.
(!6.c)*
The NRC will audit the TMI-l control room to assure all corrective actions are implemented prior to restart.
O.
CONCLUSIONS Based on our review of the licensee's submittals and other clarify-ing information, we conclude that with the corrections required prior to restart, the potential.fot operator error leading to serious consequences as a result of human factors considerations in the control room is sufficiently low to permit restart of TMI-1.
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We require the licensee to address deficiencies needing further analysis for cotimum selections as part of the detailed control room design review requireo by Item I.D.1 of NUREG-0737, and will expect final resolution of these deficiencies on a schedule to be prooosed l
by the licensee as part of the detailed review, and submitted for NRC l
accroval.
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"e UNITED STATES eJ!'. %,, [,1 NUCLEAR REGULATORY COMMISSION nPPENDfX Y
.usmscros o.c.2osss
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Septs ber 16. 1980,
Docket No. 50-289 Mr. R. C. Arnold Senior Vice President Metropolitan Edison Company 100 Interpace Parkway Parsippany, New Jersey 07054
Dear Mr. Arnold:
En:losed is a copy of a draft of our Human Factors Engineeri,ng Control Roc = Design Review of TMI-1. We would like to arrange a. meeting during the week of October 6,1980 to discuss the report, your cornents, and corrective actions you propose.
Sircerely.
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Robert W. Reid, Chief Opera,ing Reactors Branch 64 Division of Licensing En:lesure:
Draft c: w/en:losure:
See next page l
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P Metropolitan Edison Company cc w/ enclosure (s):
Mr. Marvin I. Lewis Dr. Walter H. Jordan 6504 Bradford Terrace 881 W. Outer Drive Philadelphia, Pennsylvania 19149 Oak Ridge, Tennessee 37830 Walter W. Cohen, Consumer Advocate Dr. Linda W. Little Department of Justice 5000 Hermitage Drive Strawberry Square,14th Floor Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17127 Holly S. Keck Robert L. Knupp Esq.
Anti-Nuclear Group Representing Assistant Solicitor York Knucp and Andrews 245 W. Philadelphia Street P. O. Box P York, Pennsylvania 17404 407 N. Front Street Harrisburg, Pennsylvania 17108 John Levin, Esq.
Pennsylvania Public Utilities Comm.
John E. Minnich, Chairman Box 3265 Dauphin Co. Board of Commissioners Harrisburg, Pennsylvania 17120 Dauphin County Courthouse Front and Market Streets Jordan D. Cunniagham, Esq.
Harrisburg, Pennsylvania 17101 Fox, Farr and Cunningham 2320 North 2nd Street Atomic Safety and Licensing Appeal Board Harrisburg, Pennsylvania 17110 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Theodore A. Adler, Esq.
WIDOFF REAGER SELK0WITZ & ADLER Atomic Safety and Licensing Board Panel P. O. Box 1547 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17105 Washington, D. C.
20555 Ms. Marjorie M. Aamodt Docketing and Service Section R.D. #5 U.S. Nuclear Regulatory Commission Coatesville, Pennsylvania 19320 Washington, D. C.
20555 Ms. Karen Sheldon Robert Q. Pollard Sheldon, Harmon & Weiss 609 Montpelier Street 1725 I Street, N.W. - Suite 506 Baltimore, Maryland 21218 Washington, D. C.
20006 Chauncey Kepford Earl B. Hoffman Judith H. Johnsrud Dauphin County Commissioner Environmental Coalition on Nuclear Power Dauphin County Courthouse 433 Orlando Avenue Front and Market Streets State College, Pennsylvaaia 16801 Harrisburg, Pennsylvania 17101 Ms. Frieda Berryhill, Chairman Ms. Ellen R. Weiss, Esq.
Coalition for Nuclear Power Plant Sheldon. Harmon & Weiss Postponement 1725 I Street, N.W.
2610 Grendon Drive Suite 506 Wilmington, Delaware 19808 Washington, D. C.
20006 Mrs. Rhoda D. Carr Mr. Steven C. Sholly 1402 Marene Drive 304 South Market Street Harrisburg, Pennsylvania 17109 Mechanicsburg, Pennsylvania 17055
Metropolitan Edison Company ~
Mr. Thomas Gerusky Ms. Jane Lee Bureau of Radiation Protection R.D. 3; Box 3521 Department of Environmental Resources Etters, Pennsylvania 17319 P. O. Box 2C63 Harrisourg, Penn f vania 17120 Karin W. Carter, Esq.
l 505 Executive House Mr. G. P. Miller P. O. Box 2257 Mr. R. F. Wilson Harrisburg, Pennsylvania 17120 Mr. J. J. Barton Metropolitan Edison Company Honorable N k Cohen P. O. Box 480 512 D-3 Main Capital Building Middletown, Pennsylvania 17057 Harrisburg, Penntylvania 17120 G. F. Trowbridge, Esq.
Dauphin County Office Emergency Shaw, Pittman, Potts & Trowbridge Preparedness 1800 M Street, N.W.
Court House, Room 7 Washington, D. C.
20036 Front & Market Streets Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace Licensing Manager Department of Environmental R: sources GPU Service Corporation ATTN: Director. Office of Radiological 100 Interpace Parkway Health Parsippany, New Jersey 07054 P. O. Box 2063 Harrisburg, Pennsylvania 17105 Pennsylvania Electric Company Mr. R. W. Conrad Director Technical Assessment Vice President, Generation Division 1001 Broad Street Office of Radiation Programs Johnstown, Pennsylvania 15907 (AW-459)
U. S. Environmental Protection Agency Miss Mary V. Southard, Chainaan Crystal Mall #2 Citizens for a Safe Environment Arlington, Virginia 20460 P. O. Box 405 Harrisburg, Pennsylvania 17108 Mr. Robert B. Borsum Babcock & Wilcox Government Publications Section Nuclear Power Generation Division State Library of Pennsylvania Suite 420, 7735 Old Georgetown Road Box 1601 (Education Building)
Bethesda, Maryland 20014 Harrisburg, Pennsylvania 17126
- Ivan W. Smith, Esq.
Mr. David D. Maxwell, Chairman Atomic Safety & Licensing Board Panel Board of Supervisors U.S. Nuclear Regulatory Comission Londonderry Township Washington, D. C.
20555 RFD#1 - Geyers Church Raod Middletown, Pennsylvania 17057 Ms. Kathy McCaughin Three Mile ~ Island Alert. Inc.
U. S. Environmental Protection Agency 23 South 21st street Region III Office Harrisburg, Pennsylvania 17104 ATTN: EIS COORDINATOR Curtis Building (Sixth Floor)
Mr. L. W. Harding 6th and Walnut Streets Supervisor of Licensing Philadelphia, Pennsylvania 19106 Metropolitan Edison Company P. O. Box 480 Metropolitan Edison Company Middletown, Pennsylvania 17057 ATTN:
J. G. Herbein, Vice President P. O. Box 542 Reading, Pennsylvania 19603
Metropolitan Edison Company '
Mr. R. J. Toole Allen R. Carter, Chairman Manager, TMI-l -
Joint Legislative Comittee on Energy Metropolitan Edison Company P. O. Box 142 P. O. Box 480 Suite 513 Middletown, Pennsylvania 17057 Senate Gressette Built.ng Colurtia, South Carolina 29202 Mr. W. E. Potts Radiological Controls Manager, TMI-l Daniel M. Pell, Esq.
Metropolitan Edison Company ANGRY 32 South Beaver Street P. O. Box 480 Middletown, Pennsylvania 17057 York, Pennsylvania '17401 Mr. I. R. Finfrock, Jr.
William S. Jordan, III Esq.
sersey Central Power & Light Company Harmon & Weiss Madison Avenue at Punch Bowl Raod 1725 I Street, NW, Suite 506 Morristown, New Jersey 07950 Washington, DC 20006 J. B. Lieberman, Esq.
General Counsel Berlock, Israel & Liberman Federal Emergency Management Agency 26 Broadway ATTN: Docket Clerk New York, NY 10004 1725 I Street, NW Washington, DC 20472 Mr. J. J. Colit:
Plant Engineering Manager, TMI-l Metropolitan Edison Company P. O. Box 480 Middletown, Pennsylvania 17057 York College of Pennsylvania Country Club Road York, Pennsylvania 17405 Mr. G. K. Hovey Director, TMI-2 Metropolitan Edison Company P. O. Box 480 Middletown, Pennsylvania 17057 Mr. B. Elam Manager, Plant Engineering, Unit 2 Metropolitan Edison Company P. O. Box 480 Middletown, Pennsylvania 17057 Mr. Richard Roberts The Patriot 812 Market Street Harrisburg, Pennsylvania 17105 Governor's Office of State Planning Mr. R. W. Heward and Development ATTN: Coordinator, Pennsylvania Manager, Radiological Control, Unit 2 Metropolitan Edison Company State Clearinghouse P. O. Box 1323 P. O. Box 480 Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 4
k
~
l Human Facters Engineering Control Rocm Design Review Three Mile Island '- Unit 1 During the week of July 21-25 a human factors engineering design review of the TMI-l control room was conducted. The review was performed by the Human Factors Engineering Branch, Division of Human Factors Safety. The review team was assisted by human factors consultant Harold E. Price of Biotechnology, Inc.
The follcwing sections sumr. sri:e the staff's observations of control recm design and layout, and of the control room operatfors interactions with that environment. Where possible, observed deficiencies were given a subjective rating based on the potential for that deficiency to induce an operator error during performance of a critical activity. These ratings are divided into three categories:
1.
Serious Concern - Human / System performance degradation with serious poten-
~
tial safety consequence.
l 2.
Mcderate Concern - Human / System performance degradation with moderate l
potential safety consequence.
l t
3.
Other Concerns - These require an evaluation by the licensee for future resolution.
8 e
O g
,g
~
i
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2 IT{L i
JL i
1.0 Annunciators / Alarms a.
System lacks a separate, audible alarm ackncwledge/ silence control.
This in combination with the one acknewledge signal' permits operators to acknowledge alarms without reading alarm windows.
t (Category 1)
~
b.
There is a minimal annunciator prioritization (Reactor Trip /
Turbine Trip) and tiles with blue cerners associated with En-gineered Safeguards Actuation System (ESAS). Other system annun-ciators with safety significance have no priority. Some blue markings on ESAS alarm tiles are readily identifiable.
(Category 1) c.
Scme annunciators tiles have busy legends.
(Category 2,)
2.0 Process Computer a.
CRT display of poor quality and could increase the probability of reading error.
(Category 1)
~
b.
Process computer capability is limited and its Vintage raises question of reliability of information presented to operators.
(Category 1) c.
Neither the CRT display nor the alarm printer util.ize color coded displays. c (6ategory 3)
~
d Computer backup control panel.is not used by operators. (Category 3) 3 4
p I
a
,y e
~
- 1 3.0 Controls (General)
Controls (J handle, etc.) located near front edge of console a.
could be inadvertently activated.
(Category 1) b.
Set points knobs on Bailey controllers do not Itck, and can be actidently rotated.
(Category 2) c.
Violation of plant convention for auto / manual positions on some multiple position rotary controls (Sync. Scope and Voltage Reg-ulator). (Category 1) d.
Legend switch covers are interchangeable.
(Category 1)
Legend indicators contain numerous burned out bulbs.
(Category 2, e.
f.
Many illuminated legend switches are difficult to read.
(Category 1)
"J" handle switches are frequently in a position contrary, to the g.
flag indicator color.
(Category 3) i h.
Bailey controllers indicate demand signal rather than valve posicion.
(Category 2)-
l 4.0 Displays (General)
'a. panel legend lights do not provide positive i..dication because of poor contrast with panel background, especially for certain green colored tiles. (Category 1) b.
Glare is present on all vertical indicators resulting in reduced readability.
(Category 2)
Normal operating ranges or set points are not indicated on vertical c.
meters.
(Category 2)
1
.4.
d.
Normal or desired position in strings of meters does not line up for easy monitoring.
(Category 3 )
E e.
Most meters fall at mid-scale position.
(Category 1) f.
For some moter driven valves, an open circuit breaker inhibit:
valve position indication (i.e. valve position cannot be determined).
(Category 1) g.
Bailey meter scales do not meet basic human engineering standards (scaleinternalwerepeor).
(Category 3)
~
h.
Backlighted legends are difficult to read. Rcom lighting is dim, contrast is minimal, lettering is crewded and busy and discolora-
~
tion on scratched surfaces is frequent.
(Category 2).
- i. No lamp test capability on control boards or panels.
(Category 1) l e
m
h r.
l 5.0 Labeling (General) 1 j!
a.
Color meaning is not consistant.
(Category 1) 1 b.
Mimicing is used minimelly.
(Category 3)
L l
c.
In general, labels are use.1only at the component level, not at the
[
group, function, system or panel level.
(Category 1) d.
The use of colors labels is not consistent, for example, black / white background and print. (Category 2) l, l
e.
Makeshift labeling was observed on many components including penciled
~
i on switch nomenclature, hand letters labeled and vertical meter scale value and the use of dyno tape.
(Category 1)
L f.
Labels are not all permanently attached.
(Category 1) g.
Little or no use of demarcation lines to separate systems, subsystems, functional grouping, etc. (Category 1) h.
Labels are wordy, because the function of a system is repeated on each switch of a group.
(Category 2) l 6.0 Control Display Relationship l
6.1 General - Related controls and displays do not consistently have both nomenclature and comoonent designation.
(Category 1) 6.2 Makeup and Purification System a.
Makeup pumps are not grouped together.
(Category 2) b.
Lacks positive indication of flow when makeup pump is running.
Indication by an kr.eter only that pump is runnin'.
(Category 2) en SO
.amee.me e a-=
mm
-e,gs---g
.,_,w--
e p
e-e..%.e.
45 e.--w-----,?-e w
pg---9
--9 a
n-w
-m-t+
wi+
-e
i c.
Cannot see se31 leak strip chart recorder wnen using see! injection
~
fl ow.
(Category 3; d.
Dual purpose mater for RC Pump seal aP and Lab Seal DF has different scalis which could be confusing.
(Category 3)
It is impossible to verify a required reading of 3 e.
Flow Meter which has Scale Values of 0 to 16 (x 10)gpm flow on the RC.Makaup (Category 1) f.
Boration capability is on the 1.iquidiWasta System which is remote to main control console (LWS). (Category 3) g.
Letdown flow meter is in gpm while scale on controller is in percent and must be converted before setting.
(Category 2) h.
There is no Engineered Safeguards / Safety Irdection annunciator window.
(Category 1) l 1.
Engineer Safeguards Actanion Panel has blue status lights which are difficult to interpret as Feing "on."
(Category 1) l
- j. Valve positions (containment isolation) at bottom at Engineered Safeguards l
Actuation Panel can't be seen from main console. Also, there appeared to be no color sequence or pattern to help check which valves should be opened or closed.
(Category 1) k.
No direct indication on a Dccay Heat Removal (DHR) system is apparent.
(. Category 1) 1 a
O
- .a e
~w.,
.m
.y._
~,,.
7 l.
CHR temp and DHR cooler temp indicators are side by side but i
have different scale multipliers.
(Cat' gory 2 ;
e LPI valve alignment is not sequentially organized or grouped on m.
panel.
(Category 3) 1 n.
CH, 5, 6, 7 valve controls.are not included in mimic.
(Category 2 )
6.2 HVAC System
^
a.
Train "A" controls are on right and train "S" controls are on left side.
(Category 3) b.
No separation of demarcation of grouped handle control switches (9 in a rew).
(Category 2)
Five trend recorder's (air ficw) are at top of panel (6'6") with c.
excessive glare which requires standing on a stool and lifting covers to be read.
(Category 3)
- d. Labeling does not contain infor=ation which indicates time required for depressing and holding m.ru21 fan start control to stars fan (varies by fan, 30 to 90 sec.).
(Category 3) 7.0 Sound Lcyc1 Readinns a.
The IBM - Selectric printer is 65 db.8 while typing. This level is 5 to 6 dbA above ambient and 4 to 5 dbA above most alarm levels.
l (Category 2) l b.
Main control board alarm is below ambient noise level.,(Category 1)
\\
t
4
$J[h,..
- r..:,
c.
Panel Left (PL) alarm is only 1 dbA above ambient noise level. (Category 1) d.
Right Panel Front (PRF) alana is only 1dbA above ambient noise level (Category e.
Liquid Maste System alarm is belcw ambient noise level.. (Category 1) 8.0 Other Observations e
i a.
Diesel Generator Governor has no indication on J handle switch for fast / slow speed control which is inconsistant with other speed controls.
(Category 2 )
l l
b.
Unrelated " Reactor Building Emergency Cooler B&C" displays are located in the center of the diesel panel.
(Category 3 )
l c.
On CHR system, controls for loop A and S were not associated with their dis' plays which are located approximately 8 fiet away.
(Category 2)
~
i d.
One CHR indicator and control switch which are located on loop B panel l
actually belong to loop A panel.
(Category 3
~
e.
Discrimination between systems and subsystems is difficult because of lack of use of demarcation lines and color coding.
(Category 1) f.
Auxiliary Feedwater system lacks a ficw meter. (Catego'ry 1) 1 g.
The ICS system is spread out over 3 panels.
(Category 3) h.
Control / display arrangements for ICS (feedwater, steam level) are not apparent.
(Category 2)
9 9.0 Remote Shutdown Panel (RSP) l a.
Is not independent of the control R'com - some actions are required in control room.
(. Category 1) b.
No emergency lighting. '(Category 1) c.
Comunication is by sound powered mike with no mike in area.
Cor=unication is also by Center (Xey kept in CR).
(Category 1) i E
d.
No scott-air packs near RSP.
(Category 2) 10.0 Shift Supervisor Office No emergency lightin9 is provided in this office. (Category 3) a.
b.
No scott air packs are stored in this office. '(Category 3) i 11.0 Cc c:unication in Control Room a.
Only one non-dedicated outside telephone line.
(Category 3) b.
No sound powered mikes am readily available (Categ' cry 1) c.
!!eaknesses in radio comunications with technician outside the CR.
(Category 1) d.
Sece inoperable page telephones in the plant area. Some areas in plant am not, reachable by phone. (Citagory 2) e.
Page system unintelligible in some areas of plant due to ambient
~
noise levels. (Category 2).
l l
W
~'O' i
12.0 Control Room Equipment Three Scott Air Packs are kept in the CR, but them are eleven people plannet a.
to be in the CR during emergency operations. (Category 1) b.
Air refill bottles are stored 3 floors below the CR. Elevator failures makes transport of airpacks difficult. (Category 3) 13.0 Tech Support Center a.
No airpacks are available. (Category 1) b.
No emergency lighting is provided. (Category 1) 14.0 E.mergency Procedures Iccediate action steps are too detailed som with an excessive num::er c/ ste;:
a.
required to be completed i=ediately.
(Category 3 )
b.
Steam Line Break procedure is wHtten as an abnor-al procedum rather than an. emergency procedure. (Category
)
Some steps which require 2 operators to implerent are not noted. (Category 3) c.
i
- d. 'Some procedures, ha.ve~ notes..before s'ymptons which are actually action,
steps. Many notes, in procedures am actually steps. (Category 3)
- e. Some procedures reference control and display labels by. names different from the names actually ': sed on the labels. (Category 2)
r f
. !?1};(1
- J1 i
15.0 Lighting Lighting wa's not specifically designed for reading labels, displays and a.
meters. (Category 2) b.
Direct glare from overhead lights on both controls and displays made readability difficult.
(Category 2)
No lighted exit sign in the control rocm. (Category 2,)
c.
General Comments a.
No formal system. exists for providing operators feedback about suggestions made.
b.
Sub-cooling instrumentation is not in place and operati.;.
c.
In-core thermccouples (te ) have been connected to the process computer, s
a monitoring program has bcin written and the system is in the checkout p rocess. An NRC team wi_11 review the functionability of the system from a human factors engineering point-of-view before restart.
l i
NRC eoav 335 U.S. NUCLEAR REGULATORY COMMIS$10N 47 77)
BIBLIOGRAPHIC D ATA SHEET flUREG-0752 2 TaTLE ANO Su8 TITLE (Aca votume No, d morconstel
. (Leave otan el ilVREG-0752 Control Roca Design Review Report for T?tI-1 a REC;PieNT S ACCEssieN Nc.
I 7 AuTwCR.Si
- s. DATE REPORT Cev LETEC t
l1983 l
- EAa MCNTH Decer.ber 9 PER80AMING ORGANIZATION N AME AND M AILING ADORESS stactuae J.o N8 l OATE REPORT ISSvEC Office of fluclear Reactor Regulation, Division of Human vosm jvsaa Factors Safety / Division of Licensing December 1980 5 lLesve otanal S. Leave otann o
- 12. SPONSCRING ORGANIZ ATION NAME ANO VAILING ADORESS (Inciuoe I.o Coori
- 10. PROJE CT T ASK. WORK UNIT NO U. S. tiuclear Regulatory Commission it coNTaAc7 NO Washington, DC 20555
14. Lee e oms
- 15. SUPPLEVENTARY NOTES
- 16. ABSTR ACT !200.voras or ess)
Based on our human factors engineering review and evaluation of the TiiI-l control room, we conclude that correction of the deficiencies herein identified and discussed prior to restart will permit safe operation of the TMI Unit i nuclear plant. Prior to restart, we will arrange to audit the control room to ensure all human factors engineering improve-ments are implemented.
l I
- 17. (E Y WOR OS AND OCCUME NT AN A LYSIS 17o ICENTIFIE RS OPEN-ENCEO TERMS 13 AV AILABILITY $T ATEMENT 19 SE CU R 6 7Y C L A $3 # Tr',5 Too r*/
21 NO CFPl*0E3 fio restrictions on distribution.
- o sEcupiTY class - r s ose,
- =aiCE 5
NSC FC4V 33$ 7 77'
I 2
ei 1
q UNITED STATES OF AMERICA
{
NUCLEAR REGULATORY C0t1 MISSION BEFORE THE AT0"IC SAFETY AND LICENSING BOARD In the Matter of
)
)
)
METROPOLITAN EDIS0N COMPANY,
)
)
)
(Three Mile Island, Unit 1)
)
k CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF TESTIMONY IN RESPONSE TO CONTENTIONS," dated December 22, 1980, in the above-captioned proceeding, has been served on the following, by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Comission's internal mail system, this 22nd day of December,1980:
- Ivan W. Smith, Esq., Administrative Mr. Steven C. Sholly Judge 304 South Market Street Atomic Safety & Licensing Board Panel Mechanicsburg, Pennsylvania 17055 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Mr. Thomas Gerusky Bureau of Radiation Protection Dr. Walter H. Jordan, Administrative Dept. of Environmental Resources Judge P.O. Box 2063 881 W. Outer Drive Harrisbu'rg, Pennsylvania 17123 Oak Ridge, Tennessee 37830 Mr. Harvin I. Lewis Dr. Linda W. Little, Administrative 6504 Bradford Terrace 2
Judge j
Philadelphia, Pennsylvania 19149 5000 Hermitage Drive Raleigh, North Carolina 27612 Metropolitan Edison Company ATTN:
J.G. Herbein, Vice President George F. Trowbridge, Esq.
P.O. Box 542 Shaw, Pittman, Potts & Trowbridge Reading, Pennsylvania 19603 1800 M Street, N.W.
Washington, D.C.
20006 Ms. Jane Lee R.D. 3; Box 3521 Karin W. Carter, Esq.
Etters, Pennsylvania 17319 505 Executive House P. O. Box 2357 Walter W. Cohen, Consumer Advocate Harrisburg, Pennsylvania 17120 Department of Justice Strawberry Square,14th Floor Honorable Mark-Cohen Harrisburg, Pennsylvania 17127 512 0-3 Main Capital Building Harrisburg, Pennsylvania 17120 w
- ?.
i i
Thomas J. Germine Deputy Attorney General Division of Law - Room 316 j 1100 Raymond Boulevard j
Newark, New Jersey 07102 Allen R. Carter, Chairman John Levin, Esq.
I Joint Legislative Committee on Energy Pennsylvania Public Utilities Comm.
Post Office Box 142 Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 29202 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 Montpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 21218 Theodore A. Adler, Esq.
Chauncey Kepford WIDOFF REAGER SELK0WITZ & ADLER Judith H. Johnsrud Post Office Box 1547 Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17105 433 Orlando Avenue State College, Penr.sylvania 16801 lis. Ellyn R. Weiss Harmon & Weiss Ms. Frieda Berryhill, Chairman 1725 I Street, N.W.
i Coalition for Nuclear Power Plant Suite 506
-i Postponement Washington, D.C.
20006 2610 Grendon Drive Wilmington, Delaware 19808 Ms. Marjorie M. Aamodt R.D. #5 Daniel M. Pell, Esq.
Coatesville, Pennsylvania 1020 Attorney for ANGRY 32 South Beaver Street j
York, Pennsylvania 17401
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission
.g/hf,Ogg Washington, D.C.
20555 J sep7 R. Gray
/
uns(el for NRC St.aff U.S. Nuclear Regulatory Commission ATTH:
Chief, Docketing & Service Br.
Washington, D.C.
20555 t
Karen P. Sheldon, Esq.
c/o Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006
..