ML19260C799

Comments in Support of Amended Contention 4 & New Evidence Re Rejected Contention 1.Urges That Licensee Info Flow in Event of Accident Should Be Available to Public.Svc List Encl

ML19260C799
Person / Time
Site:	Three Mile Island
Issue date:	01/15/1980
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19260C797	List: ML19260C796 ML19260C799
References
NUDOCS 8002060110
Download: ML19260C799 (5)

Text

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UNITED STATES OF AEERICA NUCLEAR REGULATORY COhhISSION BEPORE THE AT0bIC SAFETY AND LICENSING BOARD In the Matter of METROFOLITAN EDISON COMPANY, et. al. Locket No. 50-289 (Three Mile Island, Unit 1)

COEMENTS IN SUFIORT OF AME1DEENT OF AAMODT CONTENTION 4 AND NEW EVIDESCE REGARDING REJECTED CONTENTION 1 SUBJECT TO BOARD AFIROVAL FOR CONSIDERATION Aamodt contentions Nos. 3,4,5 and 6 deal primarily with our concern that radioactive releases from TMI-1 which would endanger the health and safety of people in the path of these releases will, without suitable safeguards, not be reported with the timeliness or accuracy needed to allow endangered persons to take appropriate defensive action.

The licensee's mechanism for information flow, both in the case of an emergency and other abnormal events, is consistent with our concern because management approval is required before information related to radioactive releases is forwarded to the NRC and to the public. This is demonstrated by statements in the licensee's emer-gency plan which a1]ows the possibility of censorship, distortion and delay in providing information needed to assure the health and safety of the public:

1. Licensee's statement on p. 11, Liter 6 (Guidelines of Abnormal Events other than Emergency Classifications, Appendix B, Metropolitan Edison Company Emergency Public Information Flan for TMI Nuclear Generating Station) where licensee states that investment community confidence can be enhanced by effective communication, and -

2. Concern for public sensitivity, p.10, . items 2 and 3, which might cause "a causal relationship" to be inferred between a nuclear emergency and "insignifigant prior incident."

Intervenors respectfully request that Aamodt contention 4 be amended to read as follows (added portion underlined):

4. It is contended that licensee has not made provision for timely dissemination of information in the event of accidental release of airborne radioactive gases or particulates. It is contended that licensee must make information available to the public which will allow appropriate action to be taken to protect persons, livestock, food-stuff and feed in the event of a discharge of significant proportions.

O

All data and riant overating_rersor.nel observations relative to all radioactive releases must be transmitted immediately and s imult_an eou s -

lv to the 1.RC, Pennsylvania Derartment of Environmental Resources,_

the commissioners of Lauphin, York and Iancaster Counties and the licen see's managem ent._ lt is further contended t"at licensee must provide this capability before restart of TEI-1.

Appropriate interpretation of this data by county authorities clearly will pose a problem for licensee. However, eppropriate guidelines for evaluations and public response can be provided by URC and Pennsylvania Department of Snvironment Resources.

Regarding Board's rejection of Aamodt contention 1 (psychological testing of operators and management, drug abuse,etc.);intervenor respectfully directs attention to 'rccently published study NUREG C640 (Chree Mile Island, Unit 2, Radiation Irotection Frogram, Report of the Special Fanel, December,1979), particularly to the language on

p. A-6, para. 2:

'lHe stressed that in his opinion these problems were not caused by lack of technical capability, but rather by a lack of sensitivity or awareness..."

Also para. 5 continuin6 to p. A-7, Meeting wita Siurray Miles:

"Mr. . Miles believed that major problems were attitude and ornagement control. He stressed that previously there had been a lack of accountability and discipline in the organi-zation. . . . . He also mentioned there was a serious morale problem.

Mr. Eiles stated that OFU/ Met Ed upper management had not recognized this problem earlier..."

Also pnA-7, para 4 Meeting with Faul Ruhter: D D (j f l

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"He indicated that a strong, tough manager... cA lu u ua sj Jdb dL, h) lack of proper evaluation by GFU/ Met Ed of the technicians being supplied by ESS." (identified as problem crea)

Further, p. A-9, para.2:

"Mr. Wilson stated that the primary requirement for the new head of radiation safety was strong _ management skills."

Further discussion placed more emphasis on personality: "Jensi-tive, aware and concerned" than on professional training.

Earlier, the Kemeny Report stated on p. 8 para 3 .that "the fundamental problems are people-related problems and not equipment problems'." And in para. 4, "we do not mean to limit this term to shortcomings of individual human beings -- although those do exist."

(Emphasis added.)

If indsed "short comings" of human beings ~ can effect the operation of the plant and jeopardize the; health and safety vf the general public as well as the workers in the plant, it would seem that these person-alaty traits should be identified and screened by appropriate and 1930 029

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' scientific means in hiring and promotion practices. Reaction time,

, ability to work under pressure, decision-making ability, visual acuity, attention span, fatigue, ability to follow a sequence of orders, honesty, sobriety, responsibility appear as likely candidates .ds variables of the man part of the man-machine interface.

It would a'ppear that the manaEement of nuclear generating plants are far behind other industries in the application of principles of human behavior as a function of complexity of the task. As an example, United Airlines has been using a program of psychological testing including the Stanine Battery of Stanford University administered by a professional at the doctoral level. (EUREG 0578 compares nuclear power plant shift supervisor with a pilot stating, p. A-4, " supervisors should be trained and required to supply the pilot's thinking and decision making..."

Regarding possible drug ube by.. operators or others employed at nuclear generating plants, evidence only available since the pre-hearing conference was reported in the media.of a drug ring operating among security force at the Trojan plant in Oregon, operated by Iortland General Electric Company. This is evident,1y underinvestigation by by the NRC and involves apprc,ximately twelve guards as well as suspic-ion of an additional twelve to fourteen guards. This new evidence .

adds additional importance, it seems, to the sabateur incident at Surry in that the latter is no longer a singular case.

Respectfully submitted, Y

,Marj LL 1 ks%Y ie M. Samodt Dated, January 15, 1980 J '$

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$ 4P g \ f ;*3 UNITED STATES OF AlERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AWD LICENSING SOARD ,

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In the Matter of )

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GTROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

.(Three Mile Island Nuclear )

Station, Unit No. 1) ) ,

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n T SERVICE LIST j du' u a Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Board Panel Commission U.S. Nuclear Regulatory P. O. Box 3265 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter 3. Jordan Assistant Attorney General Atomic Safety and' Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House S81 West Outer Drive P. O. Box 2357 Cak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little Robert L. Knupp, Esquire Atomic Safety and Licensing Assistant Solicitor 3 card Panel County of Dauphin 5000 Hermitage Drive P. O. Box P Ealeigh, North Carolina 27612 407 North Front Street Harrisburg, Pennsylvania 17108 James A. Tourtellotte, Esquire Office of the Executive Legal John E. Minnich Director Chairman, Dauphin County Board U.S. Nuclear Regulatory of Ccmmissioners Commission '

Dauphin County Courthouse Washington, D.C. 20555 Front and Market Streets Docketing and Service Section Office of the Secretary Walter W. Cchen, Esquire C.S. Nuclear Regulatory Consumer Advocate Commissicn Department of Justice Mishington, D.C. 20555 14th Floor, Strawberry-Square Harrisburg, Pennsylvania 17127 1930 031

Jordan D. Cunni.ngham, Esquire Karen Sheldon, Esquire Attorney,for Newberry Township Sheldon, Harmon & Weiss T.M.I. Steering Committ' e e Suite 506

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2320 North Second Street 1725 Eye Street, N.W.

Harrisburg, Pennsylvania 17110 Washington, D.C. 20006 .

T:e 4cre A. Adler, Esquire Robert Q. Follard U~ lof f E2ager SelkCwitz 5 Adler Chesapeake Energy Alliance  :

?. O. Ecx 1547 609 Montpelier Street

.Tarrisburg, Pennsylvania 17105 Baltimo~re, Maryland 21218 Ellyn Weits,. Isquire Chauncey Kopford

.cheld on , Harnon & Weiss Judith H. Johnsrud Guite 506 - Envircn= ental Ccalition en .

1725 Iye Street, F.W. Nuclear Pcwer

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Tashington, D.C. 20006 433 Grlando Avenue State College, Pennsylvania 16301 Steven C. Sholly 304 South Market Street Marvin I. Lewis Mechanicsburg, Pennsylvania 17055 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 i Frieda 3erryhill ~

Chairman, Coalition for Nuclear Uetiggip .TrSicir12ge, Esquire .

Pcwer Plant Postponement Sha9: Sittnan, Fotts & Trcwbridge 2E10 Glendon Drive IS C C C M *.S tie e t l - ?f .~. W *l. 'l = r l a

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.;ilmington, Delaware 19808 i:achington, D. C. 2CC36 ..

Tolly S. Keck Legislation Chairman Anti-Nuclear Group Representing

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st Philadelchia Street

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{0 g fu Tork, 72nnsylvania 17404 "

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