ML20063M627
| ML20063M627 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/10/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8209150304 | |
| Download: ML20063M627 (3) | |
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- i-UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION B_efore the Atomi_c Safety and LicensInq Board W)
FFICE OF SECRETARY In the Matter of
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OCKETg ERVICE
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CLEVELAND ELECTRIC ILLUMINATING
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Docket Nos.
50-440 COMPANY, et al_,
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50-441
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(OL)
(Perry Nuclear Power Plant,
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Units I and 2)
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SUNFLOWER _ALLIAN_C_E et al.
HQTION TO SUBMIT AN ADDITIONAL. CONTENTION 1
Intervenor Sunflower Alliance et. al. hereby moves the Licensing Board to grant it leave to amend its Petition for Leave to Intervene by submitting the additional contention detailed below. This contention is based on recently published research; therein lies the good cause for late filing.
Recent studies, documented in Science News, July 31, 1982 at 69 (attached),
Indicate that unnatural shif t rotations may increase the likelihood of errors made by workers. Experiments show that workers adapt more easily to a forward i
i shift rotation and to less frequent shift rotations.
Sunflower Alliance is concerned that PNPP workers, particularly control room operators, may be forced to work unnatural shif t rotations. This may lead to human error in the operation and maintance of the plant. Human error is known to be a problem which can degrade the safety of nuclear power plants.
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i The Applicants' FSAR does not detail the shif t rotations required by workers. However, such information should be readily available through discovery.
l Therefore, Sunflower Alliance contends that Applicants should design shif t rotation schedules in conformance with circadian principles, as identified in the Science News article.
9209150304 820910 gDRADOCK05000 g]
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Sunflower Alliance has met the good cause requirerient of 10CFR 2.714 for this late filing. This contention is based on a recent (July 31) article in a credible pubilcation, Scl_ enc _e News. The other factors IIsted in 10 CFR 2.714 are also favorable to the admission of this contention. This is the only proceeding in which Sunflower Alliance is a party; no other party has raised these concerns. The consideration of this issue will certainly aid in the development of a sound record; it is important that issues which could affect the safe operation of Perry be resolved before the plant begins to operate. Although the inclusion of this contention may broaden the issues, any delay caused thereby will have minimal impact, since a hearing date has yet to be determined.
Thus these factors favor the admission of this contention into this proceeding, and Sunflower Alliance et. al. prays that the Licensing Board is so moved.
Respectfully submitted,
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lb D4niel D. Wilt,' Esq.
Aktorney for Sunflower Alliance Inc.
P.O. Box 08159 Cleveland, Ohio 44108 (216) 249-8777 PROOF OF SERVICE This is to certify that a copy of this Motion to Submit an additional contention has bben mailed to all persons on the Service List on this 10th day of September, 1982.
Da,niel D. Wilt, Ehq.
Attorney for Sunflower Alliance Inc.
O
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synchronized, cxpl:ining why the 21-day Punclung the biological timeclock schedui, wa mo,, satisiscto,y cnd p,od.
uctive than the 7 day schedule.
It was 4 a.m. when the accident at Three or advance-without becoming "desyn-According to Czeisler, there is no single Mi:e Island power plant occurred, and the chronized*;in fact, people are constantly ideal schedule for all of industry, but it is s..
employees en duty had that day " rotated" advancing their sleep by an hour a day to essential that these basic physiological 53 shifts, switching from the day shif t to the conform to the earth's 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> schedule. principles be considered in the design of night shift. Poor human performance has But when people rotate shifts Czeisler any schedule that could interfere with since been imp!!cated as a major cause of says, the change in sleep cycle is too sleep.The newly formed Center for Design th? cccident (SN; 2/23/80. p.122). Abnor-dramatic; the system becomes desyn. of industrial Schedules, he says, will be ex-m:lly high accident rates in other indus-chronized and begins to " free run"- to amining regulations that involve work tries-trucking and navy, for example-drift forward on its natural 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> cycle scheduling where safety is an issue-Fed-5 have also been linked to human error. And until it is back in phase.
eral Aviation Administration and Nuclear increasingly, researchers have lmen look-As tong as the system is out of phase,the Regulatory Commission regulations, for ing fo unnatural shif t rotation as a possible trough of the alertness cycle occurs dur-example.
c,mse of occupational mishap.
ing waking hours, explaining shilI workers' According to Charles Ehret, a biologist Scientists have now applied some basic complaints about exhaustion; the same at Argonne Nationa! Laboratory in Illinois, principles of circadian rhythm-the natu-desynchronization is the cause of jet lag. FAA and NRC regulations currently pay no ral sleep wake cycle-to the design of an Because the internal 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> clock tends attention to circadian principles. Based on actual industrial work schedule, and they naturally to delay sleep,it is much easier his own survey of the American power in-report that a more natural rotation pattern to adapt to a shift rotation that requires dustry, he says, at least half the power improves worker satisfaction and her.Ith sleep delay - a forward rotation. Back-plants are rotating their workers the and t!so causes an improvement in jcb ward rotation (like eastward jet travel) re-wrong way, causing sleep deprivation and performance.
quires that sleep be advanced, which in dangerous desynchronization. "We cannot Accordmg to Charles A. Czeisler of liar-turn forces the internal sleep-wake cycle pinpoint the circadian contribution to the v:rd University and the Boston based to drift all the way around the clock to get accident at TMI or to any single maritime Center for Design of Industrial Schedules, back in phase-a process that,at an hour or ainraft accident," he says,"but there's one in four American workers works a day, may take a week or more. Some no doubt that cognitive function, visual i
something other than the standard day-workers, Czeisler says, complain of never acuity, and psychometric performance are shif t; z nd many ol those who rotate shilts adjusting to a new shift;even a forward ro-way, way down under these circum-do so in a way that violates the natural tim-tation requires a few days to become re-stances."
-WHerbert ing of sleep and wakefulness.The workers at Great Salt Lake hiinerals and Chemicals Corp. in Utah, the site of the experiment, Cancer drugs: A surface attack had for 10 years rotated every week to the preceding shift -from days to nights to Cancer drugs have long been thought to that adriamycin attached to the beads was s
evenires to days, etc. With the coopera-kill cancer cells by acting on their DNA. not able to leak into cancer cells and to act tion of the company, Czeisler and his col-Now one of the most important cancer on their DNA, and that agarose beads leagaes-h1artin C. hioore Ede of ilarvard drugs, adriamycin, appears also to act on without adriamycin attached were not Medical School and Richard M. Coleman of their plasma (outer) membranes, Thomas able to kill cancer cells. Thus adriamycin Stanford Medical School-changed the R.Tritton and Gene Yee of Yale University appears capable of dest roying cancer cells schedules of 85 workers:33 began rotating School of Medicine in New ilaven, Conn.,
solely by interacting with their plasma to a later shif t every week, and 52 rotated report.
membranes, Tritton and.Yee conclude.
to a later shif t every three weeks. The re.
During the past several years scientists J.A.R. Mead, deputy associate director of scorchers compared the subjects to 68 have begun to suspect that adriamycin the National Cancer Institute's Devel-non-rotating shift workers on measures of might kill cancer cells more than one way. opmental Therapeutics Program, says he job sitisfaction, health, personnel turn-What's more, they have learned that vari-agrees with the conclusion after reading over and productivity.
ous activities of the plasma membranes of the report in the July 16 Sc ENCE.
The results, reported in the July 30 Sci-healthy cells can be regulated by adriamy-There are also practical implications to ESCE. indicate that 70 percent of the work-cin. Tritton and Yee wanted to determine it, Tritton explains. Adriamycin exerts ers preferred forward rotation; those who whether adriamycin might be able to de.
serious toxic effects on the hearts of rotated weekly showed a e percent im-stroy cancer cells simply by acting on cancer patients, probably by interacting I
provement in satisfaction, while those their plasma membranes.To test this hy.
with heart cell DNA. lf adriamycin could be who rotated only every three weeks pothesis, they chemically attached ad-manipulated to act only on the plasma showed an 87 percent improvement. The riamycin to insoluble agarose beads (syn-membranes of cells in a cancer patient's latter group also showed an improvement thetic polymeric material) that were too body, it might well destroy the patient's in health,though they still fell short of the large to get into cells. They exposed cancer cells yet spare the heart cells of any controls. In addition, personnel turnover cancer cells to the adriamycin-bonded undesirable effects. Ilowever, because decreased, and productivity increased 22 beads. The cancer cells died. They per-agarose beads are a material foreign to the percent-a gain that was maintained nine formed more experiments to make sure human body, they would probably be re-months following the study.The company o
od jected by a cancer patient's immune sys-o hos since adopted the new rotation
,cies,ow tem, making it necessa y to attach some f
s schedule for the entire plant.
l l
on other material than the beads to adriamy-The circadian principles underlying the N
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cin to get it to act on a patient's plasma schedule design are fairly simple, Czeister ocH, o on a o membranes. " Plasma membrane proteins l
says. Because the natural sleep-wake cy-are one possibility," Mead suggests.
l cle, controlled by oscillations in deep o
Tritton.infact sees thecellsurfaceasa M
body temperature, tends to run about 25 l
'"> g promising target in the design of a new i
hours (SN: 7/3/82. p. 7), the natural ten-9"O generation of anticancer agents." Mead dency is to go to sleep later and later. But.
m o-c-y concurs: 1 could see a surface attack on a most people have the capacity to adapt to a tumor cell as a possible development c!
c ch1nge of one or two hours a day-delay Adriamycin linked to polymeric matrix.
the future."
-J A. Treichel
$cbec h JULY 31,1982 69