ML19310A193

Addl Response to Sc Sholly Fourth Set of Interrogatories Re Contention 15.Includes Info Re Plant Operators' Roles as Part of Operating Procedures & Design of Control Room. Certificate of Svc & Cover Ltr Encl.Related Correspondence

ML19310A193
Person / Time
Site:	Three Mile Island
Issue date:	05/09/1980
From:	Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
References
NUDOCS 8006060253
Download: ML19310A193 (12)

Text

Lic 5/9/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S ADDITIONAL RESPONSE TO INTERROGATORIES (FOURTH SET) FROM STEVEN C. SHOLLY RELATING TO CONTENTION NO. 15 INTERROGATORY NO.15-006 To what extent do plant operators play a role in the develop-ment of operating procedures, including procedures for emergency situations? Do operators actually write such procedures? What is the extent of their input into plant operating procedures?

RESPONSE

Plant operators play a significant role in the development of procedures. These include normal operating, emergency and abnormal procedures. Once a procedure is written it is submitted to the l l

Plant Operations Review Committee ("PORC") for final approval. All procedures are reviewed annually by the operators and are revised accordingly. Also, when a procedure is found to be deficient on the job, the operator initiates a Temporary Change Notice ("TCN")

or Procedure Change Request ("PCR") to correct it; these must be PORC-approved. The initial plant procedures were written by the operating crews and reviewed by the PORC.

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INTERROGATORY NO.15-010 Specify the bases upon which the control room for Unit 1 was designed. Provide descriptions for all factual bases and assump-tions utilized in developing the design for the Unit 1 control room.

RESPONSE

No formal compilation of design bases and criteria exists. A summary of the design process is as follows:

The design of the Three Mile Island Unit 1 control room was accomplished by researching the design of plants which preceded the design of TMI-1, reviewing the individual fluid and elec-trical system designs to determine which instruments required control room readout, which equipment required control room control, and which items were used most frequently during plant startup, power es, shutdown, and during plant upsets and transients. i..is information was gathered by the responsible Design Engineers through the normal process of design evolution.

To determine an efficient physical arrangement of those devices located in the control room, use was made of a physical mock-up. This mock up consisted of paper facsimiles of the  ;

devices to be mounted on the control boards, which could be easily rearranged. Numerous conferences between the Design Engineers and Metropolitan Edison's Station Superintendent, Operations Superintendent, and Senior Reactor Operators using the control console mock-up and performing simulated plant operations resulted in agreement among this team that the physical arrange-1 ment decided upon was logical, promoted ease of operation, and provided the operators with the control and indication they needed 1

to accommodate routino plant operation, transients, startups and plant upsets.

At the conclusion of this exercise, a drawing was prepared of the physical arrangements, and this drawing was supplied to the control board fabricator. As fabrication of the control boards progressed, periodic visits to the fabricator's shop by the Design Engineer and plant operating personnel further con-firmed that the arrangement was logical and considered operator /

control panel interface. See also Licensee's response to Inter-rogatory Nos.15-011, -021, -022, -050 & -056.

INTERROGATORY NO.15-024 Specify each instance of where procedures specify one measure-ment unit and the measurement unit on the display in um -ontrol room is in another type of unit.

RESPONSE

Licensee has not attempted to review all procedures and con-trol room displays for the purpose of answering th.is interroga-tory. However, there are no known instances where procedures specify one measurement unit and the measurement n: tit on the con-trol room display is in another type unit. Past p'ractice has been to revise the procedure when a discrepancy of this type is discovered (see Licensee's response to Interrogate,ry No.15-006).

Licensee has initiated a comparison of procedures and control board nomenclature (including units of measurement). This review is in progress and is designed to identify discrepancies of the type described in this interrogatory. Results of this review are anticipated in early August 1980.

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INTERROGATORY NO.15-028 i

To what extent does the simulator on which TMI operators are trained differ from the control room of Unit 17 With respect to these differences, how does the training of Unit 1 operators en-sure that these differences are communicated to the operators?

How does operator training ensure that negative transfer of learn-ing does not occur with respect to differences in design of the simulator and the Unit 1 control room?

1 l RESPONSE Licensee's operators are trained on a simulator located at the B&W Training Center, Lynchburg, Virginia. Since the accident at TMI-2, all of Licensee's operators have received instruction in the B&W simulator training module which provides an overview of guidance for operators based on analysis of the TMI-2 acci-dent, and exposes operators to simulated, unannounced plant abnormal and emergency conditions.

Although control room configuration of the simulator differs from the Unit 1 control room, the nuclear steam supply system, associated systems instrumentation, and currently installed transient response provide adequate fidelity for acquisition of procedural and control skills. The simulator instructor provides orientation on the simulator and describes the differences between the simulator control room and the TMI Unit 1 control room. In addition, the procedures for operation of TMI Unit 1 are utilized at the simulator by the students during the training. This em-phasizes the diagnostic skills training of the operator.

The training provided to the TMI Unit 1 operators is de-scribed in.Section 6, TMI Unit 1 Restart Report. In addition to the simulator training, the operators are trained in control and procedural skills,-utilizing the TMI Unit 1 control room, a mock-

up of the TMI Unit 1 control room recently installed in the TMI Unit 1 Turbine Building, and while in the classroom slide pro-t jections of the control board. The training in control room manipulations at the simulator is thus transferred to the Unit 1 control room. In addition, each operator is individually orally tested in a formal "walkthrough" (audit) which encompasses test-ing of his knowledge of the TMI Unit 1 control panel layout, functions, and procedural usage.

INTERROGATORY NO.15-033 Describe the extent of information available to the reactor operators at the operator's desk in the Unit 1 control room.

RESPONSE

Information readily available to the operator includes the following:

1. Alarm Response Procedures

2. Technical Specifications

3. Abnornal Procedures

4. Emergency Procedures

5. Final Safety Analysis Report

6. Revision Review Book

7. Primary and Secondary Chemistry Records

8. Steam Tables

9. Pump Curves Available close by in the control room are operating and health physics / chemistry procedures, manufacturers technical manuals, I

system flow diagrams, and electrical schematics.

INTERROGATORY NO.15-036 Provide assurance that the procedures associated with pres-surizer PORV and associated block valve reflect the same label nomenclature as the labels on the control room panels.

RESPONSE

See Licensee response to Interrogatory No.15-024.

INTERROGATORY NO.15-041 Provide evidence that operator training programs develop ap-propriate visual search strategies for operators to ensure effec-tive response to emergency conditions.

RESPONSE

The TMI Unit 1 operators are evaluated in their effective response, including visual, to emergency conditions as described in Section 6, TMI Unit 1 Restart Report. In addition, the TMI Unit 1 operators are evaluated after the procedures lectures and by preliminary operational examinations administered prior to the audit examination described in Section 6 of the TMI Unit 1 Restart Report. Visual search strategies, per se, are not taught.

INTERROGATORY NO.15-049 Describe Licensee policies and procedures regarding the re-placement of burned out alarm and control indicator lights in the control room. If such lights are not replaced immediately upon discovery of their burned out conditions, provide reasons there-for and explain how such a practice protects the public health and safety.

RESPONSE

Burned out control indicator lights are replaced immediately upon discovery by the operator. Alarm lights are tested at each l

shift change by the operator and any lights found to be defective /

burned out are immediately replaced.

INTERROGATORY NO.15-061 Identify any mechanisms within Licensee's organization which provide a systematic review of operator performance and provide suggestions for improvements in control room design.

RESPONSE

At the present time, Licensee is conducting a study of Unit 1 control room design and layout from a human engineering stand-point. This program will provide suggestions for control room improvements.

Operator performance is an ongoing review process. Each year, all licensed operators must pass a company-administered written and oral exam. In addition, during simulator training periods, each group of operators is evaluated by Licensee's super-visory personnel and by Babcock and Wilcox Company personnel.

INTERROGATORY NO.15-070 According to NUREG/CR-1270, volume I, at pages 90-2, simulator training accounted for only 5% of the time that the crew involved in the TMI-2 accident spent in training. The report points out that a significant degree of training in procedural skills acquisi-tion and control skills acquisition are needed by reactor operators, and that a high degree of fidelity in simulation with respect to console configuration and system response is required for such skill acquisition. The report further asserts that accuisition of proceduz il and control skills cannot be accomplishec. with the B&W simulation facility due to a lack of fidelity with the TMI-2 control room. In the light of these facts, discuss in detail the presence or lack of fidelity of the TMI-l control room with the B&W simulator and the degree to which any dissimilarities may im-pact on the acquisition of procedural and control skills (for a discussion of what these skills entail, see the referenced pages of NUREG/CR-1270, volume I) .

RESPONSE

The simulator training is only a part of the training provided TMI Unit 1 operators for acquisition of procedural and control skills. See Licensee's response to Interrogatory No.15-028.

INTERROGATORY NO.15-075 To what extent does Licensee's review of LER's, Abnormal Occurrence Reports, and other operational data relevant to control room operations incorporate human factors engineering perspectives, so as to ensure that the underlying causes of personnel error are determined and the cause source corrected so as to prevent future occurrences of the same or similar errors?

RESPONSE

With respect to information generated by other nuclear power plant stations, no specific procedure controlled the systematic review of such information prior to the TMI-2 accident. Cur-rently operating experience information is reviewed by the Plant Analysis Section of Systems Engineering to determine if events that have occurred at other operating reactors have safety sig-nificance and are applicable to TMI. Events involving operator error are reviewed to determine relevance to TMI, and are for-warded as an action item to be reviewed by operators, as ap-propriate. Those events that appear to have been affected by

• l plant design are sent as an action item to the engineering depart-ment to determine if a design change is necessary.

)

Operating information in Licensee's own reports receive addi-tional review and dissemination to that identified above both prior to report release and after report release. See also l Licensee's response to Interrogatory No.15-013. l Respectfully submitted, l

l SHAW, PITTMAN, POTTS & TROWBRIDGE l

l

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By

y ,

Ro5ert E. Zah & '

Dated: May 9, 1980

Lic 5/9/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

i

)

l METROPOLITAN EDISON COMPANY ) Docket No. 50-289

' ) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE i I hereby certify that copies of " Licensee'c Additional i

Response to Interrogatories (Fourth Set) from Steven C. Sholly i

Relating to Contention No. 15", were served upon those persons I on the attached Service List, by mailing copies, first-class, postage prepaid, on this 9th day of May, 1980.

sL & 7 L o

/R~bert E. Tahler '

l

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Dated: May 9, 1980 .

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart) m (Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esqture John A. Ievin, Esquire Chairman Assistant Counsel Atanic Safety and Licensing Pennsylvania Public Utility Ccmn'n Board Panel Post Office Box 3265 U.S. Nuclear Pegulatory Comnission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atanic Safety and Licensing 505 Executive House Board Panel .

Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atcmic Safety and Licensing of Ccmnissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Paleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Legal Director em M u te U. S. Nuclear Regulatory Ocmnission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pernsylvania 17127 Docketing and Service Section Office of the Secretary U. S. Nuclear Pegulatory Ccmnission Washington, D.C. 20555 1

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. o Jordan D. Cunningham, Esqujre Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against hu: lear T.M.I. Steering Ocmnittee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506

Washington, D.C. 20006 Theodore A. Adler, Esquire Widoff 1%ager Selkowitz & Adler Pobert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Lhion of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nuclear Sheldon, Harnon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801 Steven C. Sholly Marvin I. Iewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Cail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Iagislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Pepresenting York 245 West Philadalphia Street York, Pennsylvania 17404 r

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May 9, 1980 Mr. Steven C. Sholly 304 South Market Street Mechanicsburg, Pennsylvania 17055 Re: Thr.ee Mile Island Unit 1 Docket No. 50-289 (Restart)

Dear Steve:

I enclose Licensee's additional responses to your Con-tention 15 interrogatories. Copies of signed affidavits for these responses are not enclosed, but will be forwarded soon.

Sincerely, Robert E. Zahler Enclosure

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