ML20069G048
| ML20069G048 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/24/1982 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8209280370 | |
| Download: ML20069G048 (15) | |
Text
o s ,
DOCKETED USNRC September 24,,g9 e 27 gbs7 UNITED STATES OF AMERICA Orqc: - .,, ._
. e. q n t; ' v NUCLEAR REGULATORY COMMISSION ,
Before the Atomic Safety and Licensing Board ,
In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441
)
(Perry Nuclear Power Plant, ) -
Units 1 and 2) )
APPLICANTS' ANSWER TO " SUNFLOWER ALLIANCE ET AL. MOTION TO SUBMIT AN ADDITIONAL CONTENTION" In a motion dated September 10, 1982, intervenor Sunflower Alliance, Inc. et al. (" Sunflower") submits yet another late-filed contention. This contention asserts:
Applicants should design shift rotation schedules in conformance with circadian principles.
According to Sunflower, PNPP workers, particularly control room operators, may be forced to work unnatural shift rotations. This may lead to human error in the operation and maintenance of the plant. Human error is known to be a problem which can degrade the safety of nuclear power plants.
As in the case of its other late-filed contentions, Sunflower has failed to show good cause for its tardiness. It has also failed to demonstrate a basis for the contention as well as a nexus between this latest late contention and the Perry facility. The contention must therefore be denied.
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a I. TIMELINESS The factors to be considered in determining whether to admit late contentions have been reviewed in many previous filings and need not-be revisited again here. Applying these factors to the facts, however, shows that Sunflower has not met its burden. The good cause advanced by Sunflower is a short article which appeared in the July 31, 1982 issue of Science News.b! The article discusses a study which evaluated shift rotation and circadian rhythms. The study found that a rotation system where workers rotated to succeeding shifts (forward in time) improved job satisfaction, health, personnel turnover, and productivity. If the Science News article had been the first widely available publication to reflect this idea, Sunflower's good cause argu-ment might have had merit. Unfortunately for Sunflower's posi-tion, the idea has been discussed in the popular press for more than four years. I Wholly apart from the general topics of circadian rhythms (which was recognized as long ago as 17292/) and internal biological clocks (first noted in the 1930'sS/), the idea of adverse l b/ Science News articles have been the basis for a number of late-filed contentions. See Ohio Citizens for Responsible Energy Motion for Leave to File its Contention 14, dated July 6, 1981; Ohio Citizens for Responsible Energy Motion for Leave to File its
~
Contentions 17, 18 and 19 (April 22, 1982). 2/ Raloff, " Biological Clocks -- How They Affect Your Health", 78 Science Digest, 62, 64 (iiov. 1975). ,
$! Takahashi and Zatz, " Regulation of Circadian Rhythmicity", 217
( Science 1104 (September 17, 1982). 1
e effects from shift rotation due to its disturbance of circadian rhythms has been studied and discussed for more than four years. A 1978 study by National Institute for Occupational Safety and Health examined this question.S[ While it might not be fair to hold Sunflower accountable for a study by a relatively obscure government agency,5/ this study and the arguments on shift rota-tion have received significant coverage in the popular press for several years. A quick survey located the following:
- 1. Bennets, " Studying the Woes of Working Nights", New York Times, April 5, 1978, at C1, 18.
- 2. " Study Finds Health Perils in Rotating Work Shifts", New York Times, pecember 27, 1978, at A13.
- 3. "Rx for Shift Workers", Human Behavior, March 1979, at 36.
- 4. Slade, " Shifting the Dangers of Shift Rhythms", Psychology Today, April 1979, at 107.
There are, of course, many other articles in scholarly journals
~
on the same topic. With this readily available literature, Sunflower cannot claim that the July 3, 1982 Science News article was its first available opportunity to learn about this issue. Clearly, had it A/ Tasto and Colligan, " Health Consequences of Shift Work", DHEW/NIOSH Report No. 78-154 (March 1978). See also Johnson, et al. "The Twenty-Four Hour Workday", DHHS/NIOSH Report No. 81-127 (1981) at 261-268. E! Cf. Memorandum and Order (Concerning Motions to Admit Late Contentions), July 12, 1932, slip op, at 5 ("We therefore agree with OCRE that it would be unfair to charge it with current knowledge of all NRC publications....") 4 chose to do so, Sunflower could, with reasonable diligence, have uncovered this issue prior to filing its original petition for leave to intervene. While the July 31, 1982 article calls attention to another study in this area, it merely adds to the existing body of literature on the topic. The recent appearance of such cumulative information is not good cause for Sunflower's late filing. Nor was the issue so esoteric as to escape notice by intervenors in other proceedings. For example, during the February 1981 evidentiary hearings on the Three Mile Island Unit 1 Restart (Docket No. 50-289 SP), one of the intervenors dis-cussed the shift rotation issue in her direct testimony and sought to elicit information on the issue during her cross-examination of otheb witnesses. Testimony of Intervenor Marjorie Aamodt at 7, foll. Tr. 12,931; Tr. 11,651-2, 12,244-5, 12,434-9, 12,952-3; 13,159-61. Sunflower's failure to raise the iss- earlier stems from its failure to think of it, not from the lack of readily available literature on the subject. Lack of diligence cannot be equated with good cause. I Sunflower's showings on t,he other timeliness factors do not help its causew While no other party has raised the issue, Sunflower has not shown why the NRC Staff's actions (discussed below) will not protect its interest. The motion does not even allege that Sunflower's participation will assist in developing [ a sound record; instead Sunflower claims that consideration of theissuewillaidibdevelopingasoundrecord. The appropriate i i j > s
issue is Sunflower's abilities,b[ a subject on which the motion is silent. Finally, Sunflower alleges that any delay will have
" minimal impact". Sunflower bases this claim on the absence of a hearing date. Since the predicate for the claim has now disappeared,2/ Sunflower's argument likewise disappears.
In sum, Sunflower has not met its burden of demonstrating that its late filing is justified. II. BASIS AND SPECIFICITY . Sunflower seeks to relate the shift rotation issue to this proceeding by its assertion that " unnatural shift rotations
... may lead to human error in the operation and maintenance of the plant." A reading of the Science News article and the report on which it is based fails to disclose the connection. And the only area of possible concern, operator fatigue, has already been addressed by NRC.
The Science News article starts off with a reference to the TMI accident,which began at 4 a.m. on a day, according to the article, that the employees had rotated shifts. The article's first paragraph concludes by stating that " increasingly, researchers have been looking to unnatural shift rotation as a possible cause of occupational mishap." The implication is that l b! See Memorandum and Order (Concerning Sunflower's Late-Filed Radiation-Dose Contention), September 15, 1982, slip op. at 3, 1! Memorandum and Order (Concerning Scheduling), September 16, 1982.
the new study reported by Science News deals with shift rotation and occupational mishaps. It does not. Even the description of the underlying study set forth in the Science News article makes clear that accidents and occupational mishaps were not studied. According to the article, the study looked at comparisons of " job satisfaction, health, personnel turnover and productivity." Nothing there deals with accidents, occupational mishaps or safety. Had Sunflower examined the study itself, rather than merely a news report of it, the scope of the study would have been clear. Since the Science News article provided the reference (Science, July 30, 1982), Sunflower's lack of research is hard
. to understand.
The underlying Science article,S! a copy of which is attached hereto, is clearly aimed at issues unrelated to occupa-tional mishaps caused by shift rotation. We report that rotating shift workers are often dissatisfied with the features of their schedules that violate circadian principles, and that when schedules are introduced which taken into account the properties of the human circadian system, subjective estimates of work schedule satisfaction and health improve, personnel turnover decreases, and worker productivity increases. 217 Science at 460. None of these factors would seem to have a direct bearing on safety issues. S/ Czeisler, Moore-Ede and Coleman, " Rotating Shift Work Schedules That Disrupt Sleep Are Improved By Applying Circadian Principles", 217 Science 460 (July 30, 1982).
The only bit of information in the study which might affect safety at Perry is the possibility of workers falling asleep on the job. According to the Science report, workers on rotating shifts fell asleep at work more often than workers who did not rotate. Id. at Fig. 1 and 461. Fatigue is an appro-priate concern for nuclear plant workers. However,.it is a concern which has already been addressed. For example, in February 1980, the NRC Staff recommended guidance on nuclear power plant staff working hours, based on recognition that fatigue can adversely affect worker performance. IE Circular No. 80-02 (February 1, 1980).1! In NUREG-0737,
" Clarification of TMI Action Plan Requirements" (November 1980), . the Staff stated that the administrative procedures shall include as an interim measure the guidance set forth in IE Circular No.
80-02 until additional information is developed on "the effects of overtime beyond the generally recognized normal 8-hour working day, the effects of shift rotation, and other factors". NUREG-0737 at I.A.l.3-1. On February 18, 1982, the NRC published a policy statement concerning fatigue of operating personnel at nuclear reactors. 47 Fed. Reg. 7352 (1982). A revised version of the policy statement was published on June 1, 1982. 47 Fed. Reg. 23836 (1982). Applicants have also committed to include in their admini-A/ Interestingly, when this Circular was sent to Applicants, a copy was also mailed to Sunflower's counsel. Letter from James G. Keppler, Director, Region III to Cleveland Electric Illuminating Company, dated February 1, 1980.
strative procedures limitations on maximum working hours. Safety Evaluation Report, NUREG-0887, S13.5.1.4 (May, 1982). Sunflower has failed to recognize these actions (even though it had actual notice of them) or indicate why they are inadequate. Sunflower has also failed to recognize that The Cleveland Electric Illuminating Company, which will. operate the i Perry facility, has used the same shift rotation system since before World War II, and has never received a complaint. In addition, many of the Perry operating personnel 'come from the Navy nuclear program. See, e.g. FSAR Table 13.1-3; ACRS Subcommittee Tr. 94, 139-141, 144-145 (June 28, 1982); ACRS Tr. 101-102 (July 8, 1982). Navy personnel have generally worked on rotating shifts. Of course, if individuals cannot adapt to rotating shift work, they would not choose to work on a job which requires it.
.One final point on fatigue is the lack of any evidence that the TMI accident was caused by fatigue. Despite the speculation of a link which appeared at the end of the Science News article (but which did not appear in the Science report), the only study to deal with this issue found there is no evidence that, at the time of the accident, the actions and inactions of the operators were significantly influenced by fatigue, disorientation, or distractions.
NUREG/CR-1270, " Human Factors Evaluation of Control Room Design and Operator Performance of Three Mile Island", vol. 1 at 23 (January 1980). The human factors study concluded: The primary conclusion reached on the basis of this investigation was that the human errors experienced during the TMI incident were not due to operator deficiencies but rather to inadequacies in equipment design, information presentation, emergency procedures and training. Id. at v. Thus, Sunflower has failed to provide any substan-tive basis to support the primary factual underpinning of its late contention -- that fatigue somehow was related to the TMI accident. For all of the above reasons, Sunflower's late-filed con-tention on shift rotation should be denied. Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: L /:M , JA . S3 LBERG, P.C. Counsel for Applicants 1800 M Street, N.W., Suite 900 South Washington, D.C. 20036 (202) 822-1000 DATED: September 24, 1982
,,- W' l
lo leaI systems. Osm: tic swelling of cv- 5. H. Setuncier enc J. P. Rosenbowt Proc. Airl H,. W. A. Kachadonar J. Mulier. A. Fanulstm. 3 I toplasmic s esicles Could. In pnnelpl' . . e. Arac. Sra. U.SA.15. MA) tlh soee.7L SN (1981).
- 10. M. Alabas. F. S. Cohen. A. Finietsmn. sr.
occur through a number of mechanisms. P'epamen.
- 17. M. Monia:. Mertoes I,:,wmol. 3 . 5.s3 Il9ht It t Kau=2 anc E. kaner.>. s,ot Carm. 246.
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II. H. Nahoo and E L Rosenters. J. Ger.. .C (1971L ;' includin; mobili2.ation of osmotically .in- rau,ol. 77.121 (19611.
- 19. J. Aens and R. Laiorre. E ophys. J. 28. 259 active constituents in the vesicIc. alter- 12. C. Msiser and E. kaner.J. Membr. Aiol. M.083 197to.
(1979L , Etion of vesicle membrane permeability 20. F. Orson. C. A. Hunt. F. C. Szoka. W. J. Vai; -
- 13. B. Sairr. C. Schooley. P. Saur.J. Cr11 Biol. 56. D. Papahad;opoulos. Ber**m. Aaophys. Are to Dns. or stimulation of ion pumping 15) 0973L ss7. 9 t1979). /
H. w. W. Dousias. ovoiec n H. B. Pollare. K. 21. J. P. Rosenousch. J. 3,o1. CAcm. 249. 3019 - into th. ve'icles. In the experiment rep- TacL Go*ernan. C. J. Fazoks. C. E. Creuc. N. (19741. ! resentrd te Fig. IB. osmotic swelling of R. Shulrnan. Pror. A'ert. Acod. Sci U.S.4. u. ::. Thb work mu supooned by NIH iirants 5295 19m. i the vesicle was accomplished by substj. t$. R. L. Ornbers and 7. 5. Reese.J. Cell Biol. 90. GM 9:lo.c5.5mcM :ss.ane ow :7m.c:. t I do i19611. 29 April 1982: revised 4 June 1982 tuting a pettneant solute (glucose) for a n:npermeant one (stachyos l. This is f. fermally equivalent to a biological vesi- ! cle osmotically swelling because of an } inere.tse in the permeability of its mem- Rotating Shift Work Schedules That Disrupt Sleep Are brane to cytosolic constituents, such as Irnproved by Applying Circadian Principles ions. Numerous examples already exist of Abstract. Workers on rotating shifts dislike those espects of their work schedules I vesicle swelling being associated with that violate circadian sleep-wale cycle physiology. Work schedule scrisfaction. l caocytosis (although it is not yet clear subjective health estimates, personnel turnover, and worker productivity improve i that the swelling precedes iusion). when schedules are introduced that are designed to incorporcie circadian principles. I Among these are mucocyst discharge in . Teirchymeno (13), serotonin release by The human sleep-wake cycle has between night, evening, and daydme du- ' mast cell granules (14). and granular dis- evolved on a rotating planet with a regu- ties (1). charge by Limulus amoebocytes (15). It lar 24-hour alternation between day and Numerous medical and psychosocial has also been shown that antidiuretic night. Yet within the past 50., years, the. p,roblems associated with rotating shift hormone-stimulated fusion of cytoplas- need for round-the-clock operations in work sche'oules have been reported (2), mic tubular vesicles with the luminal many industrial plants and emergency and several different approaches to the plasma membrane of toad urinary blad- services has led to major changes in the problems have been susgested (3, 4). der can be regulated by osmotic forces in day-night schedules to which 26.8 per- Because research findings (5-7)indicat. ! a manner consistent with that of vesicle- cent of the U.S. work force is exposed. ed to us that most rotating work sched-planar membrane fusion (16). Although many of whom work shifts which rciate ules are outside the range of entrainment in our system Ca ' stimulates fusion by of the pacemaker timing the human cir-promoting the close association of vesi- cadian sleep-wake cycle, we postulated cle and planar membranes, this need nat that a practical and effective intervention be its role (or its only role) in biological 80 - 4 g { c would be to resolve this aspect of the exocytosis. The possibility that in- *" shift work problem. We repon that rotal-creased levels of Ca 2 trigger fusion e) * -
/ ing shift workers are often dissatisfi:d stimulating osmotic swel?ing of vesicles ' ,
uith the features of their schedules that (by any of the mechanisms mentioned 'O-g violate circadian principles, and that abovel ments serious consideration. j ~ 1 *#- when schedules are introduced which i FREDRIC S. COHEN { 2e - 7 take into account the propenies of the Department of Physiology. Rush Medical College. j o j [/f , . , ql human circadian system, subjective esti.
; mates of work schedule satisfaction and Chicago. Illinois 61612 :s health improve. personnel turnover de-MYLts H. AxoAs ,! ep C"""**""""' D creases and worker productivity in-ALAN FisxEtsrEis Departments of Physiolsgy and 2sehO**""'c creases.
We compared 85 male rotating shift Bicphysics and Neuroscience. 4c L , workers, aged 19 to 68 (mean : stan-Albert Einstein College of Medicine. dard deviation. 31.4 10.0). uith a con-Eror . New York 10s6/ ro -
,5 , /( trol group of 65 male nonrotating day and v.A eL' ' rlii y .
/f /, "
./
swinc shift workers with comparable urer.nen ne win jobs. aged 19 to $6 (mean. 27.3 = 8.2L LE ha::. N blem or be..! Trumnce s wmei iLnem o! Lnn Press. LueTon;.
$ ie : 3 at the Great Salt Lake Minerals and
' Fi; L ( A io Cl Com:mson cf sleep-w ake Chemicals Corporation in Ogden. Utah
- DnI;U s,,ueem Sv. 3 s mr A 1 c3cie cuesuennarre responses from werkers & For 10 years at this plant weekly om.
on weekly rhase advan:e rotating shifts anc C N:.cc . 3. .m . th 'r 'Ic'?- nentcanng das and sw:n; snih wcriers. Tne shifts were rotatec ui:t each crew work- f
. . E u.c.. c ~ rur ucm rimr 12 :: in; a ;n en S hour s .n,. r.for . .e cays before rc:zan; shih deriers repened greater prer-
? be.,: .re \ D s .n. :.c . in an e.nr iem u nh 4 A ). doe- cuah:3 sier:. reu. tin; te tne pre:ecmg F hour shift. ,
6.. C Fece ce C. L Nenant Ec- 4 3:m = 2e 4. ? < (R 4 E fah:n; asicer a: Hence the schecuied work time rotatecy s
. Er e s e.c s m..nt e- u cc. .1% r % g:m , g, y < 03: ang ,Cn thf in a pr.cse act an:ing direcuen frem nign$
M-cr c; F 5 Cee .. A Fm eWem - schecue changing 10: cfien 1 *: ' = * ? O. ,, ;p g.ine G m ik gng.. ge p 3,
- at rc ..(gg. !. :o om p meme ; A % , .c e ir
! < FM <D: Tne nemre cf cm uien fer the sice* D ne o' Ine w ee r t rnW s0\inte
- I '
l15h..;r 3 Cc,e F nu+c - reat m; s h:fi s enes :: .c e: ne ear snd O
- n - . . . va:.cn *"I < OW cact b 0rter h M gn en the 'or ce-L
- nptive and health indices of Smith.
'endall and Hulin (10) and sleep-wake A pnc schedule preference questionnaires. _y 7 ', _
Jne response rate was 84 percent (11). "*" 5,, E . Before hiervention The rotators reponed s.igruficantly more T l- so . D r(l) = 26.4. P < .001) problems with i? insomnia than did nonrotators Gig. lA) . i control and 29 percent of the rotators reponed that they had fallen asleep at work at [${ 25* least ont e during the previous 3 months o A p W"k'Y Dha ** 88'ar:c* i Fig. IB). A major complaint was that ' 0' ion ,he schedule changed too often Wig.1C), . B snd 81 percent reponed that it took 2 to 4 c7 7 [""" j.
$p 7s -
j / days or more for their sleep schedule to j j adjust after each phase advance: this reluded 26 percent who said they were l[E so _ jb :y)
;7 ..
After intervention sever able to adjust befor: being rotated igain (Fig.1D). E* e - es - bf . gj / con,,,, To design a rotating work schedule *
%g hat would take into account the p oper- 0 4 ~-
- es of the circadian timing system we ocused on two key issuest the direction C mum WuHy phm celey
=- .
rotat6en >f rotation and the interval between 4&c e 75 - ihase shifts ln normal human subjects ;i 21-cay phase celey he endogenous free-running period of he sleep-wake cycle averaFes 25 hours.
.[
i f, E E S[ so - rot ation
- ut that cycle can usually be entrained *j$ 25 -
y periodic environmental time cues *S - ebich are within 1 to 2 hours of the n.dogenous period (6). Thus the typical n \ 3 ange of entrainment in man :asily ac-ommodates normal synchronization to T D - F be 24 hour peri 6d of the carth's rota- ; $ 75 ~ M ' i-5 i5 75 - m" m~ ' ion. This range allows in any ont cycle nly a small phase advance with respect
]* 50 zE -
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[$
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E 50 - ' 5,*!.*
) environmental time but a 2- to 3 hour base Jelay (12). This explains why ad-
=e
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(( z j -l - 25 - t. plation is more rapid after westbound wel(requiring a phase delay)than after [b b ' O . o o_ . astbound travel (requiring a phase ad-an:e)(13). These consirierations led us -? E - e
> conclude that work schedules that itate should do so by successive phase
,Ij Eo
, 73 _
jf 1.25 - E . elays and that the interval between [ ," 3e _
$*' { too _
base shifts should be as great as is l v actical. E _E r eq E ~s ' 5[ 25 q To test this hypothesis, we divided - g
' { *o.75
;ift workers on phase advancing work 'S > $""9 heduies into two groups and placed o -
c.50 - ' em on phase delay schedules: 33 work- Fig. 2. Measures of worker sausfaction ad prodxudty befon and aber inuoexuen of new s cont,inued to change shifts each week shih work schedules. (Al Aher expenen:e with both schedules. workers preferred delay (D)
,d f2 others rotated shifts by phase rotating schedules over the advance (A) rotating s:hedule [p(2) = 43.6. f < .001): NF. no preference. (B) There was a signincant redxuon if(l) = C.E. F < .001]in the compla:nt that la) once every 21 days (14). Before the schedule " changes too ohen" by rctators on the Ol-day phase dela) senedule but not by , ' ple me ntation of the schedule. all rotaten or the weekly phase celay schedeie or by comois <C and D) Rotaters en the 21-cay Jrkers and managers attended an au- chase delay schecule had signincantly in:reased 5:eres on eeth tne schecule satisfa:uor:ince>
3risua' pre entation on the basic prop- anc on the beahh incex lrt$1I = 4.K I < 001. ar.d rtfii = :..:. F < .01, respecovely) (D Fersonnel turnover rate dunn; the 5-mon:t stu:3 pened amen; retaun; shift werAers flehe was ies of the crreadian sicep wake cycle redxed uher the :) d>> rhase delay s:hecule was in:rocc:ed to the same range as a ha suggestions for adjusting their compa able controit roup of tienre:aun; th:': w crien m;h: iFi Fe: ash ha vesung erocanvr 1
'-~r: t er um: to the:r schedule, and each 13 nercased sign 46:antly (Sixenf 31-tesa cunn; tne cuaner seasen immedme!) foHoming tae j ened an ecacational booklet oe-introc e' 'n of the :) dav :hase celav tc:aun; schecute inlW
- 2 JC. F < .l00 aich clusteN. s::-
comtared w the previou' s I 3 ears the're were a se i .:reases it. ine $rs: Ir% = .5!.F<(00 nec for the worke 5 at this fa:iht). ane second Ir@ = 10 E ? < 63C c iners af er tne summe ere.L tmicdie anc n;nt
^
Se & erkeri pref- en:es were eva!u- clusters)(!L 'L IGiTne :ro auen ef rre:essec re: ash in:reased st;ni'.:a .m lrMFi = f.E c~ cuesucnn. ires distriruled - /< M aher nuoexux ef'he :bcas -nne ce , fc:aun sene:Je ir :cmtriser W :ne
.l i,de tr.e :n: o;utuon c. the r
nes- sa r.e renx the pres som s ci t r:er the wesers w e'c c . "e w eei? Thast acun:e sche:ue M 1 e < !Et; 2.1. N D . anc personne;
..f g ,,,f g;
'm3 qiq
r turnover and plant productivity were en. sider-tion both the nature of the work krerences maa haies alyzee 9 months after the introduction of tnd the specine needs of the workers. 1. M. J. Cor.asar.. ir. 7Ar 7.c.,r Ar Ho.,r word, the new schedules (Fig. 2. E to G1 (13). The improvements recorded on the 21- *^ L. C Johnson. D.1.1cpas. W. F. Conou. Tne workers clearly preferred the phase day phase delay schedule are consistent hoa. M. J. coman. Ecs. IDeoa-tmen cf Hea th ar,e suman semees (NIOSH) PubL No. delay direc; ion of rotation (Fig. 2A): with the results of temporalisolation .md $3N,Q*,"l $"y OS** %" fun 8 complaints hst the schedule changed clinical studies (5. 6.12. 20). Mills et cl. 2. J. kutenfrau, w. P. Colouhour.. P. Kuutt J
- too often dropped from 90 to 20 percent (20) showed that the circadian rhythms amons the workers on the 21-day phase M ii'95' i['f,",# [ [ O ",y f,'ff M of volunteers usually show a phase delav -
He#A L . set mo<r 55. i r979n J. T. saio, delay rotation schedule (Fi;. 2B). This o,16 hours m. response to an 5-hour
, sr. 5. M. Hetman. C. E. Mehoa, si,,,,a Air was associated with a substandal in. phase advance shift of schedule because Demaninun or Transmnm7,rge (Rep. so 7AA-rg.7;.3: co.,,,i,,,,
w asium,1o crease on the schedule satisfaction mdex D.c. 1977n A. Rembers. Ed. **Chronobio.op. such an abrupt phase advance is beyond ea) ficio stud.es or oil refinery shari workers - (Fig. 2C). improvements in the health the usual human range of entrainment
- index (Fig. 2D). and a reduction in per- (6). Most workers on phase advancing 3.trionomics
[. g73M77'.*pf @lgh,,T,7Coteabouc. 19 33) (1976).T. Akersteet and L. s:nnel turnover (Fig. 2E) (16). At the schedules may therefore be in a state of 3 N.*,N,.;. *M ",,'$,,#8) x;,p7,'l^,,',"J ,'*, same time the rate of potash harvesting continual forced in'.ernal desynchroniza. Jams sa .srace,1cs. L L schevmy ane F. (Fig. 2F) by men operating front-end tion (13. 21) between the pacemakers (7 llalders. Eas. (Si;tno: & boordhon. Alphen aan een Rnn. Nethertands.19so). pp. 293 3oe; loiders in the evaporation ponds and the 22) of their circadian system. 2. vokac. P. Magnu s. E. Jebens. N. 0uncerser.. rate of processed potash production in Int. A rtn. Occap. Ennron. Heahh 49. 5) (l951}. The consequences of such disruption 4. J. Aschef. Erronomers et. 739 (1978); A. Rem. the plant (Fig. 2G) also increased after in temporal organization are just begin- @p;,[,,D,' J@as A-J. Chauinona A. the introduction of the new schedule. ning to be understood. It was only re- 5. c. A. Czessne;r. thesis. stanford Universny end the increases in productivity were cently recognized. for example, that the maintained in the harvest season which $.'I. c. zunbr naIEknauer.'5c.$ normal timing and organization of sleep m. is 09sa followed the completion of our study depend on an appropnate phase relation . 6. R. A. W,ever. The Ca.rradicn $vsnem of Men (spnnrer-Verlas. New York 1979). period (17.16). between circadian pacemakers (5, 23). 7. M. C. Moore.Ece. F. M. Suizrnan. C. A. Futier. Previously three major strategies have 7sr CiocLs 7s,r nm, us: pnysioiog, of ,s, The forced disruption of phase relations cercadian Dmaar Syssem (Harvard Univ. hess. been used to address the problems of inherent in shift work schedules ac- .g. D.,8['i U^,','g;,,3%,, ,,7% go,,, g,,, adaptation to shift work. The first and counts for the previously unexplained both urban and rurai seruess: many tae rnovee perhaps most obvious, is to schedule sleep disturbances reported m. earlier . to the area from surroundrr3 states such as CAMornia. leaho. and Nevaca because ot eco. workers on straight shifts without rota- field studies (24). Failures in homeostatic aomi' 'PPonunF-tion. However. it is often di5 cult to staf regulatory rnechanisms are also associat-
. 9. In keeping with circadian terminology we use phase advances i.m io mean swis to an the night shift. and straight shift schedul- ed with internal desynchronization of the ing still results in conflictmg environ-
**','l,h c, 3, ff,"jhl,,ferenegum;g
,3 g , , ,gs e
)
circadian system (25), and chronic exter- to mean swts to a taier tour. mental synchronizers for the night work- nal desynchronization induced by light- * [i,h,f,*((J,Idi,h*$ %3"M*l. er who adopts daytime activities for so- dark phase shifts results in decreases of 5 s-earas (Rand McNany. caucaso.1969). C1al reasons on days of. The second to 20 percent m longevity in insects (26) sstrents of the efects of our interven. it. For tier..asse,y on ro:aton who comp;ei e boa m,t,,, strategy fa' ored in Europe. is to rotate and in mammals (27). In humans, the and fonos-up assessments were included (93 percent of trutaal subiects). from one shift to the next rapidly in order long-term efects of such phase shifts are 1:. C. A. C2eisler. G. S'. Tuchardsor.. R. M. Cole. to escape the consequences of partial temporal adaptation (3). However, the not known but field studies indicate that 7"p /;,C , mgegnaj g ;Mocq {iE fj _. there are more sleep and digestive disor. 13. K. E. Kkm and H. M. Wegmann. in Sicca, circadian system may be afected. even ders among workers on rotating shifts k'e @s'e"n'*[/ N [.'fe Y '/N'ie^;,,$. on rapid rotation regimens. since a (2) with some unable to tolerate the Group for . Aerospace .Research ane Develor-ch2nge from the phase advance to the schedules (2E). Concern about the poss.i- mer.t, heu2Dy sur Seme. France.1979), pp. io. i.r o.n. Ehase delay direction of a rapid rotation ble long term health consequences of 14. Tne :t-eay phase delay scLeeune was originally system resulted in sorne improvements rotating shifts is growing (29). It may be destned so tha: work hours were shifted radu-an3 ey I to hours per day for 5 cays untir the in both psychological and physiological that the application of circadian p-inci- h
,"fn,5$"'".,',"*,5g*h,Jn',5 7, , 1pP',,c*8/Q measures (19). A third strategy would be pies to the design of schedules can main- venient for the worken' family we and car to take advantage of diferences between tain the temporal integrity of the circadi-individuals in measurable properties of an system and minimize for the shift Ed,"8, e *"*",8,'"'i'd.i na ,, lcrbIeY
!$. Re:auns sh:f: schedules fo tnese workers ren.
the circadian timing system, such as worker any deinmental consequences of trah opera:ed ctrnns the potash harvest season gros seriember throush May. Dunns ine sum. rhythm amplitude (4). to select individ. circadian disruption. men mos: workm work strap eay shifts. uals with the greatest tolerance for work- it. Tr.a: these efe:ts are due to mereased toierance CH ARLEs A. CzIlsLER" of the circacian system to the work schecWe es mg or sleeping on abnormal schedules. Centerfor Design c.fIndustrial ,'QQ"@ *'l,Q*l *,',';)*'j'y',,'Q in contrast. our straten was to take Schedules. .'O Sicniford Sirect, m:ederen:e utr famm er sonai ue. e t~ advantage of those prope ties of the cir. A.c. 600, eosion. Mcsscrimsetts n.11,. 1: re.a crikely
,:ie: 13e tha: these pr,,ene, erm:rcases i.,, ,1,e3 m,,,mproductivity un:, sii l
Cadian tyStem that individuals share m and Dir:3fon o.f h(c!!h Poacy neJecrcn reuum s;aasues we e cenved h re:re. l Common the longer than M hour endog- cnd Ec.,Cclion. hcrPard Em. irersin soume ana!vus of cemars ca a tr.a: - as i to.:anch gr. rived Ori bc nM :scaies were ' enous pened and the hrn: led range of Ccmeridp. Messachusv:3 02154 en:ra:nmen: The resul's cf this f. eld {c 8g',c,8e4"y*' og trycl,l;Yl um C. Moou-hE te c-peu: a e-net:r fcano-.c after ceum.: e ! , sn.d> mcicate ina: ucrk schedules tha Depce: ment of Physioicp @;',3" f *' ica- %
- Fan ns. sc,,nu 10. -
ro: ate by phase delay witt att extended onc Sicphrsics. Ncrrard Medice nA meaen an:ceriner menor atah s s r.a: r3 a ine cc- necdc.. a9 A InICh ad eIu eeE cdct Iotallen are most Schoo.,. Sosion. Mcescchasetts C ,.' crer res oec p y ne. ,,.c rer..:e_en: er er, c< :se sa,esi.r; e
- :m e u r the prepenies of the Ricsrc M Co;tm m r.me' c 's; the 5e-" c
. = n . = d a - u = g n s,e m H eu er Sir c; Dumces c:auc cuc Ecsee ce-mwec v e.: . w e ,- e , m
- ie a ter:erc.c cl % cme m:re. e te e \- $
,-x etc e x cu a t* t w :;n of a a srec:f c u cr> . :ce . m c':ec e. we m:c ces Ce n:cr 5 wed L o m:. Scno: c
- a ' -
fr %',7',ly, }, ,[ gc <n . f M Mcc j c :c 31 oc G. : tre m c- c x r m w- e%
eF ; F. 6 eft causiera. nor for rnore tha.n a 2L C. A. Ful er. F. M. Sultman. M. C. Moo-e.Eoc. fr.ct cn c.f ine enersases m the suhacucnt cuar. Sterner 169. 794 (1976 mal Swiss-Webster and Phul} mouse ien. 26 J. Aschof.11 $ami. Paul. R. Wever. Nci,rwis. ) Insuiute cf Mec. cmc. ArstarrA ce Stress one lenses were examined by sodjum dode-sensrAs/ ira 54. 574 (19711 it h,mse hrcisa I Nanonaj Acactm) Press. 27. T. Haltierg W. L. Nelson. L. Cadotte. Jn!. C),] suuate-po}yacTylamide gel electro-k asninpor.. D.C. 1911) p.102. Cord. Fror. Jai. 3oc. Chronobol. 10. 133(19 3. [ J N. Mihi. D 5. Minors. J. M % aierhouse. J. 21. A. Aanonser., Jad. Mee. Jnrr. 2.8. C (!9396. phoresis (Fig. ]). The anows in Fig. ] pais.ot #Lonsoas 285. 433 (1974L 25. L C. Johnson, D.1. Teoas. W. P. Concuhour. B. J. Ascho!. m Enoronmenser Lacorranoloes.1. point to the 27 K $-crystallin polypeptide M. J. Colhgan. Eds. 1 eraar,rms in M orb 3scrf Assenrrscher and D. Fnrner. Ecs. (Spnnter. 5thed-les: Eferrs on Heahn and perfo maare band. This band of pro.cin was not Pres-Yerlag. Ne. York. !$7s), pp. f t.%.195. (Spectrurr., New York.1981): D. A. Hamburg.
- s. E. Rus.k anc 1. Zucker. raysiol. Ari. $9. M9 ent in the normal Swiss-WCbster lens at t157e :s C. A. Ful:cr. R. Lyoic. F. M. Sultman, G. k. Ethon. L. L. Parron. E45.. heahh and heherior (Insutute of Med. cmc. NationaJ Acad- day 1 or dav 3 but was casDy visible b)-
H. E. Aloers. E. Tercer. M. C. Moore Eoc. em> Press. %ashmrion. D.C 19C1 pp.108- day 10 and" accumulated thereafter. In , Am. J. Ps is o!. MI. R3t3 (1983): R. Lydst. W. 123. ' C. Schcene. C. A Czenier. M. C. Moore Eoc. 30. We thank the woriiers for their panicipauen: P. contrast, the 27 K S-crystallin polypep- ' Sleep '. 35} (19f41.
- p. J. Zuliev. R. % everfJ. Aschof.Pfine ers Arrh. L. Rachey for his role in esta%shms and be5mg Ilde appeared to be missing from the I
, 391. 3 i(19s!).T. Akerstedt and M. illberg. m coordmate this proyect; the company manape- ' l 7he 7warrJour Honi Wortasy. L. C. John-ment and staf for their cooperation:1). Armor. pg } ens at aU stages examined. E.X- [ son. D.1.' Tepas. W. P. Colouhoun. M. J. K. R. Faubet. A. Forrest. M. M. Testa. anc D. periments were not performed on older Compan. Ecs. IDepanment of Health and Hu. C. waison for assistance with cata analvsas: B. !. H. Colycar IH. S. Lawson. J. M Gumrdss. and mice because S-crystalhns degrade dur- ~ mar. Senices (NIOSH) Publ. No. 81 127. Gov. H. W lsoa. for preparation of inustrat.ons:L. C. i ernment Pnmms Osce washmrton. D.C.. Kilham. J. Nsusche. and K. T. Redoms for ing the process of oEaci5 cation (4* 6)- 1951) pp tic.% c4: R. E. Kronauer. C. A. manutenpt preparauon;J. ]. Thompson for edii-C2eisler. 5. F. Palaic. M. C. Moore.Edc. c. D. mg of educational matenals: and D. A. Hamburs A ITaCe of the 27 K S-crystallin po)~v-w eiumsr.. A m. J. Phis,o!. 242. R3 (19E01.
- 3. J Foret and G. Larun. in Aspects of N mee for his review of the manusenet. Peptade w'as observed as early as days 1
- Send repnm rceuests to C.A.C.
Ep.rere rs. W. P. Colouhoun. Ed. (English and 5 after birth, and considerable Lon . Press. London.19'2;. pp. 271-212. I February 1982: revised 26 Apr019g; amounts were evident by the tenth post-natal day in the BALB/c and Nakano lenses (Fig 1). Nakano mice were de-rived originally from BALB/c mice. The efiCiency of FunCtic,nal Messenger RNA for a Developmentally Nakano mouse dmlops a hereditary osmotic cataract associated with lorne egulated p-Crystallin Polypeptide in a Hereditary Cataract imbalances (7) caused by the production i of.an inhibitor of the cellular Nay-Abstract. The messenger RNAfor a 6 crystallin polypeptide with a molecularsi:e adenosine tt; phosphatase (E). Thus the
- 27 kilodahons,first detected 3 to 10 days after birth in the normalmouse lens and (e NcLano mouse cataract, was not detected in the Philly time of appearance mouse cataract for the 27 K k-crys-with \l tallin polypeptide may vary slightly with nslation in vitro. The hetero:ygous Philly lens had intermediate levels of the 27- the strain of mouse. Moreover, the de6-
- oi!altan p-crystallin polypeptide and exhibited delayed onset of the cataract. The ciency in the 27 K k-crystallin polypep- ,
ciency offunctional 27 kilodahon p crystallin messenger RNA is the earliest tide is not due to general osmotic imbal. *; ion reportedyetfor the Phillylens endpoints to a transcriptionalorposttranscrip- ances, t nal developmental defect in this hereditary cataract. Total RN A's extracted from the lenses : of Philly and control mice were tested by 'I Development of the ocular Jens is for the normal Swiss-Webster mouse and translation in a reticulocyte lysate to ! aracterized by differential synthesis of cannot be detected at all by translation in determine'whether the Philly lens lacks a F erystallins (structural proteins) and is vitro for the Philly mouse. functiona! mRNA for the 27 K E-crystal. u
.nsequently a favorable system for the The polypeptide compositions of nor- lin polypeptide. Autoradiegrams of sodi-dy of differential gene expression in l karyotic cells (1). Normally the lens is nspare Iwever,nt. the lens In certain becomesstrains of mice, opaque- 1 eay 5 cays to days 20 cays 30 cays 1 cay to cays 20 eays i 3 p s p s p s p s p a n, e w, e n, taracious-after birth. The Philly - . - .-- -_ yr - - - !
use, a derivative of the Swiss-Web-
@ E ifiv5i n. tii Ei -. $ 22 - - - l r strain. develops an osmotic cataract se:: I M M_ 9. ,7 ~.5 -. *7._ ." .. _. k1-- -
ring the fourth postnatal week (2). The r.g g ; g'~2~ 1., illy cataract progresses from an initial i C'~ ' ~ -
- 7. lt -
nt subcapsular opacity to a dense nu- QMf6 '. - 8 "T ' " . ' - ar cataract in about 1 month (3). Crys-
.$(N'* 7
lin synthesis is severely depressed in j gg, m 9 g . m. s "g..,,
!ar fiber cells of the Phi!!y cataract (4). :" O' a. - T?
'~
is appears to be caused, at least in
;. by ienic changes within the lens i'. g Q $ $
c., @7 $9i # g # W$ 5 - b&D&S@
% I *
- Gb -
- inte-fere with the translation of crys- a. s.cw Y a as 43y,
'" g @. gi h% m Q 9 p ah, g
-- = ans im rnessenger RN A's (mRNA's) d).
40 tc ie penera: reduction in crystat. s d g g* Gj k, p g.g
+
Q-# %g -
- n. , , g synines:5. 2 E.c vstallm polypepude t a rr.oietuar size near 5 kilocations -
Y, y '# h ,;,:s 4 k g$~ N 3 K: is seie:nvely rn:! sing from the F; ). Sodiur- dodecy: sulfale-poiya:r). amice reis of lens pro: ems from Smss.Weester h cua ct tf We now repori that centro!(L. Pnili> (h. E ALEE (E. anc Na..ane 4 w lenses The senses were remcn ec trem tne i u.crcsta;> pC!) Derace !! ; o c \ e ,:- eyes anc temeren;:ec in 10 rx : mer:2::c e:nare: I rN CTA anc ] pereen: soSum e enta.;
; g g , .y , g g e;m.at e c c etem whose _
p,..eb peiyaeryamice sla: Fe '!' . Jea -ere trec wnh Cc>c .assic crum ewe h (Em-4 e :in a re ce'.ened by trans!auer Rat , Tne a- ou s r em:ic tne :' M p.en s:a - - e- ace. c:be t mat ederen:e5 t'etw eer. tne tte:One eetL ific cl!* C0rt Oc Er..b i!n? eToie:r? k eTe nel '***N 0 7'e ____ ___ - -- . - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - _ _ _ _ _
September 24, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) ' 50-441
)
(Perry Nuclear Power Plant, ) Units 1 and 2) ) CERTIFICATE OF' SERVICE - This is to certify that copies of the forego.~ng " Applicants' i Answer to ' Sunflower Alliance, Inc. et al. Motion to Submit an Additional Contention'", were served by deposit in the United States Mail, First Class, postage prepaid, this 24th day of September, 1982, to all those on the attached Service List.
, i A
~'
JAY $. SILBERG Dated: September 24, 1982
[ . . NU8..S.R REGULATORY CO!EISSION4 3efora thw Atomic Sa'fety and Licensinc Board In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441
)
(Perry Nuclear Power Plant, ) Units 1 and 2 )- SERVIr 5 LIST Atomic Safety and Licensing Peter 3. Bloch, Chairman . ' Atomic Safety and Licensing Board Appeal Board Panel U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington , D. C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Lice ~nsing Board Office of the Secretary U.S. Nuclear Regulatory Commission Tf.S'. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555- . 1$. Frederick J. Shon Stephen H. Lewis, Esquire ~~
~
A'tomic Safety and Licensing Board Dffics~6f~the Executive Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regul.atory Commission Wahsington, D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Chairman Ms. Sue Hiatt Atomic Safety and Licensing OCRE Interim Representative Appea'l Board 8275 Munson Avenue U.S. Nuclear Regulatory Commission Mentor, Ohio 44060 Washington, D.C. 20555 Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing P. O. Box 08159 Cleveland, Ohio 44108 Appeal Board U.S. Nuclear Regulatory Lommission Wa shington , D. C. 20555 Donald T. E::ene, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atomic Safeuy and Licensin9 105 Center Street Appeal Ecard P aine sville , Ohio 44077 U.S. Nuclear Regulatory Cc= mission Washington, D.C. 20555 John G. Cardinal, Esquire Presecuting Attorney A:cmic Safety and Licensinc ~ Ashtabula Cou..ty Courthouse 7 3 card Panel Jeffersen, Ohio 44047 U.S. Nuclear Regulatory Ccmmissicn washi.c:en,
~
D.C. 20555 Terry Lodge, Esgaire E15 Spitzer Sul_dinc Tcledo, Ohio 43604}}