ML19350B526
| ML19350B526 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/10/1981 |
| From: | Aamodt M AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8103200739 | |
| Download: ML19350B526 (22) | |
Text
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Aamodt, f(arch 10, 1961 United States of America k ia ,'; Cos g .
Nuclear Regulatory Commission ODs.ycp Before the Atomic Safety and .icensine Board
@l A In the I.atter of I.etropolitan Edison Company, et. al. # Tc (Three hile Island Nuclear Plant, Unai b y Docket No. 50-289) : 0 9 -9 D M )m M 1,
V# ff GO Intervenor Response to Board 4 Request for Evidence that Consideration 4 of Control Roor Operator Fatigue is Appropriate In response to an order of the Board (Tr / 2 9 ?,(' )
to provide evidence that consideration of the fatigue of control room operators should be considered within
- 1. the Commission Orders of August 9, 1979 and March 6, 1980, 2.. the TMI-2 accident,
- 3. Aamodt Contention 2, and 4 in relationship to performance in the Unit 1 Control Room ~
.. .I -
'f-r the following arguments are presented: pO3 5
- 1. Containment within Commission Orders j /
The Commission Order (August 9, 1979) specifically states (Section II, 1 (e)) that zhe Licensee shall Augument the retraining of all Reactor M
, .s Operators and Senior Reactor Operators r' %,
assigned to the control room including ,- ---
training in the areas of natural cir- _
culation and small break loss of coolant ~
,, .. i-
- accidents including revised procedures a!>p
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and the TMI-2 accident. All operators S f :, !; ,
will also receive training at the B&W : .y ,
simula1.or on the TMI-2 accident and the , '
licensee will conduct a 100 percent
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slo s200737 y .
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2 l
l rexamination of all operators in these areas. NRC will administer complete examinations to all licensed personnel in accordance with 10 CFR 55.20-23 (heauirement A) and the Licensee shall (p. 7, Item 6.)
... demonstrate his managerial caprbility and resources to operate Unit 1... Issues to be addressed and training include .. . technical of operations staff. .capability
. , (Reautrement B) and in the Commission Order, March 6,1980, that the Licensee a t,* . ' t tn u shall demonstrate whether its management is sufficiently staffed, has sufficient resources and is appropriately organized to operate Unit 1 safely. (Reauirement C)
(Requirement designations have been added for the sake of discussion.)
Requirement C is clearly dependent on Requirements A and B.
Since (a). Requirements A and B have been =et by only 12 candidates following completion of the Operatcrs Accelerated Retraining Program and reviews of portions ofthatprogram,(AIMCSO (b). Letter (Paul -F. Collins.to H. D. Hukill) assumed on 11/12/81 that 38 candidates would be ready to stand licensing as a function of OARP training, /
(c). Letter (Robert W. Reid to R. C. Arnold) assumed on 11/20/81 that that number (38) of licensed operators would be only marginally sufficient to meet staffing requirements, .
(d). The number of recruits available throughout the industry is scarce (Tr. 12,062),
in order to meet Requirement C, the hours that would be worked by those who have met Requirements A and B (to stand licensing) would
3 be increased. ( The alternative of licensing operators at standards below those considered appropriate in light of the TMI-2 accident, although alluded to (Tr. 12,062 and 12,063), would not be in the interest of health and safety of the public.) How this increase in working hours would alter the pompetence of the licensed operators on Requirements A and B shohld be assessed. "The Commission Order, August 9,1979, provider consideration of "sufhiciency" of shbrt term requirements on page 12:
The subjects to be considered at the hearing shall include:
(1) Whether the "short term actions" recommended . ..
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are... sufficient to provide reasonable assurance...
This part of the order blankets situations overlooked working that threaten reasonable assurance. The increase in/ hours of control room personnel would cause a serious insufficiency in an area of central concern to the Commission.
The Narch 6 drder carries this further on page 4 :
The Board should apply its own judgment in developing the record and forming its con-clusions on these questions.
It is in this area of judgment that decrement of performance /in areas that the Commission has requested augmentation through train- ,
ing, due to fatigue can and should be considered.
In that same Order on page 3, the Commission calls the attention of the Board to identification of errors (Item 9).
This should include some attempt to-identify those asacciated with fatigue (and other stressors, as change in shift shedule).
Training is clearly related to reducing errors, however the extent to~which fatigue overcomes its positive effects should be identified. Sheduling should be arranged to effect a"real" augmentation in Requirements A and B of the August 9 Order dF as measured in the final test, _ job performance. .
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- 2. Nexus to the TMI-2 Accident The Essex Report 1 contains an entire page of fatigue effects (page .23 ) and their contribution to the accident. It is unfortunate that the Essex Corporation was unacquainted with psycholoa.ical research and findings although a number of their Se;e insu(ftuuseq member' held degrees of some sort in psychology. Thts is apparent from the inferences drawn from their observations.
Referring to page 23 , Essex discusses several operator errors during the accident as caused by " set" (para. I 2.12). Set is clearly a symptom of fatigue. For instance, NRC documents 2 refer to studies 3 of set:
fatigue results in personnel ignoring some signals because they develop their own subjective standards as to what is important.
Essex overlooks this well-established principle and faults training,b .
The operators wers using their training -- their on-the-job training --
what had happened in their recent past. (That was considered bad')
The bad part was that they were set on E singleymost easily recalled path, ignoring or not looking for other signals -- a sign of fatigue.
Zusex goes on (p.n-24 ) to infer that set prevented several decisions, including the determination that the IORY was open because these decisions were reached by personnel who were fresh to problem. Training not subject to fatigue?
Further Essex refers (p.?_4 7 2. )' to the inadequate reason-ing and problem solving at the time of the accident, while indicating that the operators lacked no ability (the shift supervisor on duty during the accident had demonstrated this ability to the highest extent of any and all operators at TMI on recent requalification examinations.)Surelythiskindofabilityshouldhaveovercome J . _
5 7Lar die b set that was due to training { hwever Appa% mh M'3ae.
34 Further, Essex studies ( Appenbx 8 ) the accident in time frames, but fails to find any signifigance in the time of the accident. The specific time of the Thl-2 accident -- five hours into the backshift -- has been documented as the " lowest" in terms of probability of correct response.4,5 4- s- p. s19 e3, P577 FL It seems incredulous that Essex Corp., with supposed expertise in the area of human behavior could have introduced their discussion of these (above) observations by dismissing any influence of fatigue -- er that Mr. Blakh, counsel for the Licensee, could have referred to this page (Tr./2920 ) as evidence to the contrary, parti-cularly with the advise of two eminent psychologists as parties in their case. Their inference relative to fatigue was based on reviewing the transcripts of several interviews conducted with control room operators.
Surely analysis of working hours would have provided a more scientific case.. (Ferhaps the oversight of studies of psychological factors of scheduling and the relationship to operator performance is not unusual, in view of the outstanding and prolonged oversight of nuclear engineers ofohuman engineering principles in control room d esign.)
Following the accident, several NRC documents have
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dealt with the aspects of fatigue. Perhaps the Inspection and Enforcement branch knows something -- or has "an educated hunch" --
0 about the work schedule at TMI-2. One document stated that excessive work hours can affect the ability of operators to recognize and cope with conditions requiring attention. NRC currently has no limits on the hours a worker can work. There is currently no requirement to assess the cauability of the worker to perform the complex function of operating a . nuclear power. plant. (emphasis added)
Capability is taken here to mean those abilities, training and knowledge available as a result of hours worked. The obvious
6 omission of study of fatigue is recognized. ,
An earlier document from I&E I comes the closest to an (F I4-33) analysis. Review of available records of past reactor trip events revealed that seven of ten reviewed incidents occurred within an hour and one half before or after a shift change. This is a signifigant indication of time effects on operator performance.
(The errors made at the beginning of the shift should be studied for evidence of shift rotation effects.)
It has been observed that operatorsr883. perate a nuclear plant from a poorly designed control / That is essentially what Dr. Christensen testified to (January 15) regarding the TMI-l control room. The training makes up for the deficiences.
When errors happen in such a situation, since training is in place, ,
something inhibits training -- for instance, fatigue, distraction.8 The inhibition due to fatigue would the be greater in proportion to the complexity of the task and the adequacy of the training.
The arrangement of the ThI-2 control room was surely complex and therefore contributed to the negatige effects on training.
Additionally the cojtgol {oog itself was/fatiguer with barely ..g dfscernable signals, glare, the need to stand almost constantly, disper'ed s parameters and noise.9 The poorly designed control room contributed to the accident through the effects of fatigue --
it physically fatigued, and its complexity enhanced fatigue effects en training.
. Oorrective actions coming out of TMI-2 accident have included suggestive. regulations and regulations relative to working hours.
I4 Circular No. 80--2 (Februaryl,1980) expressed concern for over-time work for members of the plant staff who perform safety-related functions. Shift manning in relation to hours worked is discussed and regulated in other documents. emanating out of the accident:
Eureg 0694,# 0737. On page 3-6 and 7 of Nureg 0 737 it states:
l The staff recognizes that there are diverse i opinions on the amount of overtime that would I
be considered permissible and that there is a lack of hard data on the effects of overtime beyond the generally recognized normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> working day, the effects of shift rotation, and gphgr factors. NRC has initiated studies in this
- TMr RetxfrJ Regantmass 4r dm oper.dwy Ucaoser,p.39 oM* G80 e .
7 Evidence of work weeks of 60 to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> for maintainance workers at TMI-l were obtained by alintervenor in this hearing. It is reasonable to assume that control room operators worked similar schedules. It appears that the Office of Inspection and Enforcement of JRC ehould be questioned about their interest in work schedules, ,
post TMI-2 accident, and possible relationship to the accident probed.
The control room operators had no' lunch' break and no planned pauses, which have been clearly demonstrated in numerous studies as needed to offset extremely deleterious effects of fatigue after a few hours.lO p g, , , 7,qt)'
Lack of specific reference to fatigue is missing in other studies, perhaps because no psychologists were included on their panels, specifically Kemeney and Rogovin.
- 3. Relationshio to Aamodt Contenti nn 2 In order to design a training program, the performance that is required on the job must be clearly defined. Job performance is clearly the objective and the final test.
For instance, from the. procedures that were needed during the first 150 minutes of the accident, the tasks required were defined I
and analyzed into specific skills and knowledges that are needed.
One skill needed was Perceptual Skill: p. %4 Identifying a display or control Reading a display Understanding a display This skill was then translated intc Training Objectives. p.?C EL (P. 85,86) Recognize loss of. main feedwater flow to both OTSGs e
9 9 9
8 Determine that an RCP has tripped automatically-Verify header pressure at 885 Psi Recognize a turbine trip This is what is commonly called monitoring. In designing a program to teach monitoring skills, it is helpful to know that monitoring 41Y # #'
is particularly susceptible to fatigue.1* Pean is rather weak in 1
long-term monitoring activities, such as watch-keeping or radar observation. His performance is not very reliable over long periods of time. Therefore, in training techniques will need to be devised to achieve the required degree of proficiency over the time period covered. (It is interesting to note that the Essex Corp. designates a 100% level of performhnce in meeting training objectives.)
Achieving training goals must certainly take hours on tne job and other fatiguing effects into consideration. So must testing if it is to predict job performance.
Regarding the relationship of fatigue to the teaching 1
of. knowledge required, Essex admits the effect of training on set (an effect of fatigue), in their discussion (p. 23)*. Essentially they are saying that overtraining for a wide variety of situations will withstand the effects of fatigue that tends to narrow the field of perception. It has been demonstrated that overlearning overcomes time effects f p.JW k U GME M <
Clearly Aamodt Contention 2 is concerned with job performance as stated:
It is contended that TMI-l should not open until the performance of licensee technicians and management can be demonstrated to be upgraded as certified by an independent engineering firm.This upgrading should include 100% test performance of job description with provision for retraining and retest, or discharge of those who ecunot consistently and confidently master all necessary information for safe conduct of their job description under all anticipated critical situations as well as routine situations.
'I The Commission's Order and my contention No. 2 share the same concern:
Commission: assuring safe operation of the plant through better job performance by control room operators, and management Contention 2: assuring health and' safety of public through upgraded job performance of control room operators, others and management Stancards of Commission's Concarn:
Section II, 1 (e) of the August 9 Order
> Item 6, p. 7 of the same order Item 1 and Item 2 of the March 6 Order 4
Standards of Contention 2 's Concern:
Certified by independent engineering firm 100% test performance of job description Retraining and retest to 100% or discharge Trained to all information necessary Consideration'of competence under all critical conditions Consideration of competence under all routine situations ,
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/0 Commission's concern about capability of management speaks to scheduling, hours worked, overtime, use of human resources, training and testing. as it affects job performance.
Commission's concern about training and testing relates to how it is relevant to job performance which would include all the modifiers of that performance including fatigue -- or hours on the job, overtime and shift rotation schedules.
Comm4ssion is depending on NRC licensing, Licensee's tests, NRC regulation of scheduling, and Board's recommendations.
Intervenor has found through discovery that not a single concern expressed in her contention has been satisfied througn this hearing:
The so-called independent assessment by experts was far from that.
Job descriptions have essentially not been written.
Retraining and retest is to a lower standard; discharge does not occur.
Noone knows all the information necessary. -
There is no way to test competence under critical canditions..
There is no way to test competence under all routine conditions.
One of the most routine conditions, fatigue, and how it affects perfor=ance has not even been considered in this hearing.
Intervenor is being artificially restricted to look simply at a training and testing prograc and to evaluate that program.
The program and the testing, as well as the results, are an extreme disappoint. In view of what was revealed in cross-questioning there is no assurance that the operators are better prepared.
Intervenor therefore wants to examine how lessening fatigue can optimize what training there has been. Changes in the training program appear far down the road.
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W hile training can offset some of the effectsoof fatigue, it is not possible to train away all effects. Fatigue is' powerful Qd' asked and a's"eV1'denced by findings from research, attached'. ,There;fwe g
The Board Reply, dated May 8,1980 compelled the Licensee to answer Interrogatories on length of shifts at TMI-2 and TMI'-1.
Licensee offered intervenor the opportunity to obtain these data from their files in Reading. Intervenor discovered that this was a task that could take days as was the experience of another intervenor seeking work schedules of maintainance workers.
At the August prehearing conference, this problem was raised, but no solution was forthcoming. The board appeared interested in seeing such data, but offered no help in lessening the burden.
The Commission Order of August 9 is specifically interested in job performance as the objective of adequacy of augumented training and testing, page 2:
...in order to provide reasonable assurance that the facility can be operated safely over the long term."
It can also be the final test of adequacy if evaluations of sufficiency do not take into account the identified modifiers of training and testing. Fatigue has been clearly.. identified.
Assumptions that performance,in the control room is not effected by fatigue is: clearly contrary to established findings in other related fields. Since fatigue is controllable (contrary to stress') through appropriate scheduling, to train to overcome it, which cppears far-fetched in view of tests given TMI-l personnel, would seem to be ignoring an important management issue.
The area of fatigue has gone unaddressed in this hearing, and ,
the need for study is recognized. Tr. 14432 1. 18-25.lf 12420 i lR43A
- 0ther well-identified modifiers are rtress and attitude. These are also " operational" in occurrence, however the licensee made no objection during cross-questioning, a n indication of inconsistency that serves Licensee's own purposes rather than the public's.
n
Id To divide training from operational considerations as per the NRC departcents is artificial. When the Review Committee of Metropclitan Edison assessed the retraining rrogram, there were acny discussionfof the interconnection of human engineering of the control room and training. There was an entire chapter, written by Dr. Christensen, and included on the the control room. Dr. Christensen, the human factors engineer, was a part -
of the training program review committee. The divis6cn is not between human engineering and training, or between operations and training; rather th; natural division is between man and machine. Each is a machine. We are aware of ways to make the machinets safety systems redundant; that same thinking should be applied to man. That would bring the industry thinking to a 20th century level. Ean is a archinewith redundant systems:
training, knowledge, readiness as evidenced by lack of fat 1 3ue, alertness as.. evidenced by attitudes and lack of fatigue.
All the environmental stressors that affect the man should be considered together as they interplay in making the man an adequate machine to interface with the nuclear machine. Can maintainance of the machine be considered' aside from the number of hours a piece of equipment has been in service? ^
The boa d has recognized all the elements of the contention in stating that human factors consideration should have been given this intervenor's attention, "when you take into account that it was almost half of your Contention." 4r 12,431,1. 7,8 nowever that division appears incorrect, since the litigation of human factors was solely concerned with changes that stault be make to the control
, room -- on the machine side of the man-machine interface.
Ib
- 4. Relationshin of Fatigue to Ferformance
- 1. Most experiments on vigilance reveal man as a poor monitor by demonstrating decrement in response proficiency as observation time becomes longer.
" Monitoring of Complex Visual Displays - II. Effects of Visual load and Response Complexity on Human Vigilance," Human Factors, Vol. 3 (1961) pp. 213-221. Jack A. Adams, Herbert E. Stenson and John M. Eumes
- 2. Fatigue tends to affect high-grade performance long before there are signs of physiological exhaustion. The more complex the per-formance, the more delicate the discriminations, the greater the number of sources of information which have to be attended to, the more likely the performance is to suffer from fatigue.
Effective human engineering, in facilitating the provision of information about the effects of action through various forms of feedback, can do much'to reduce impairment of performance as the
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result of fatigue.
Fatigue appears most clearly in complex performance where knowledge of results is reduced or minimal.
The above quoted from Occucational Psychology, "Vol. 32, No. 4, (O ct . , 1958) 3 In certain types of monitoring tasks, performance decrement occurs if rest paases are not allowed after work periods of 30 minuttes.
i B. O. Bergum and D. J. Lehr, " Vigilance Perf ro mance as a Function of Interpolated Rest," Journal o.f. Applied Psychology, Vol. 46~(1962),
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- pp. 425-427.
4..
Shift rotation imposes a physiological hardship on allthe workers every time the shifts are changed and may lead to a general decrease in efficiency.
Some can adapt to a six-hour change in about a week; others find the adaptation very difficult.
Kleitman, Sleen and Walefulness, p. 267 e
e- 79 ,w--. . ,,ee- r +c--
- v --w. - - -
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- 5. Companies now using rotating shift should review their scheduling problem to determine whether fixed shifts can be substituted.
If rotating shifts prove unavoidable, changes should be made infrequently.
A company with a four-shift cycle could cut the graveyard shiftdown to five hours by simply adding 20 minutes to each of the other three shifts.
H. F. Northrup, Shift Problems and Practices (Studies in Personnel Policy, Nc . 118 (Eew York : Kational Industrial Conference Eoard, Inc.)
- 6. In Sweden, researchers found many instances of failure to adjust to changing shifts. The shift workers were being forced to live in different time sequency from that of their community and of the many people to whom they were intimately related. In a study of errors made in entering figures in the ledgers of a large Swedish gas works under a rotating three-shift system, it was found that a very high number of errors occurred around 3 a. m., five hours into the shift.
Errors .did not vary either by season or by day of the week. Sam e variation appeared on the last night of the week as the first, in-dicating that the weekly rotation system was not allowing workers enought time to change the general pattern of their diurnal rhythmn.
A. Pierach, " Biological Rhythm-Fffects of Night Work and Shift Changes on the Health of Workers," Acta Medica Scandanavica (Suppl. 307),
Vol. CLII .
- 7. Boredom is psychological fatigue. The greater the change during the rest breaks or lunch hour, the less disruptive will be the effects of boredom.( Another method of counteracting boredom is by teaching the workers the value and meaning of their own job -- attitude)
Duane P. Schultz, Psychology and Industry Today, 1973, hachillin hany more references could be cited, however the conclusions are quite consistent.
My research at' Brown University was done in the area of fatigue; Resistance to Extinction as a Function of Effortfulness of Task During Acquisition and Extinction, May 1951
/f References
- 1. Nureg/Cr-1270, Vol.1 Human Factors Evaulation of Control Roo= l Lesign and Ouerator Ferformance at Three Nile Island - 2 Final Report, Prepared by the Essex Corp. for U. S. Nuclear Regulatory Co" mission 2
- 2. A. D. Swain - 1223, Scandia Labs, 8/31/77 Working Paper, Revised 1/20/78, Effects of Hours on Job on Visual Detection and Decision-haking with Implications for Nuclear Power Plant Personnel 3 McFarland, R. A. , Understanding Fatigue in Modern Life, Ergonomics, 1971 3a. Nureg/CR-1270, Vol. II, Human Factors Evaluation, etc.
4, Kenneth N. Wexley, Gary A. Yukl, Urgani zational Behavinr and industrial Psychology, 1975, Oxford,
- 5. Fleishman, Edwin A., Studies in Personnel and Indtstrial Psycholor:. ,
1967, Lorsey, Fatigue, Monotony and Working Conditions 6.
- 7. Nureg 0600, Investication into the March 28, 1979 Three Mile Island Accident by Office of Insoection and Enforcement, Investigative Report No. 50-320/79-10, Augu st , 1979
- 8. Hull
- 9. A Review of the ihree Mile Island Unit 1 Control Room From "A Human Factors Viewnoint, December 1980, Review Team: GPU, hPR, Dr. J. Christensen, Dr. T. B. Sheridan
- 10. Gilmer, B. Von Haller, Industrial _Psycholocy, WorkandCondi4 dons of Work, Harry W. Karn, Chapter 11
- 11. Duane P. Schultz, Isychology and Industry Today, 1973 Macmillan, Ingineering Psychology, Ch.11 12.
Hilgard, Atkinson, Atkinson, Psychology, 1975.Harcourt, et. al.
e
Attach. 1 Results of PQS Tests Following OARP Based on Long Data, Tr.
Passed Fai ?.ed_
Category (TMI-2 Events 12 14 Other Locas)
Based on Kelly Data, Long revisions All Categories Except 8 4 R0 Exam SEO Exam 11 2
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) )
CERTIFICATE OF SERVICE I hereby certify that copies of the "Intervenor Response to Board Request For Evidence That Consideration of Control Room Operator Fatigue Is Appropriate," which was hand delivered to, Licensee's representative by Norman Aamodt on March 10, 1981, were served upon the parties identified on the attached Service List by deposit in the United States mail, first class, postage prepaid, this 10th day of March, 1981.
AE. u Ys /~v>n o q-T Delissa A. Ridgway Dated: March 10, 1981 l
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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)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
SERVICE LIST Ivan W. Smith, Esquire- John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'n Board Panel Post Office Box 3265 U. S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D. C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic 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 Atomic Safety and Licensing of Commissioners Board Panel -
Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D. C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (3)
Office of the Secretary U. S. Nuclear Regulatory Commission
-Washington, D. C. 20555
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Jordan D. Cunningham, Esquire William S. Jordan, III, Esquire Tox, Farr & Cunningham Harmon & Weiss 2320 North Second Street 1725 Eye Street, N. W., Suite 506 Harrisburg, Pennsylvania 17110 Washington, D. C. 20006 Ms. Louise Bradford Robert Q. Pollard TMI ALERT 609 Montpelier Street 315 Peffer Street Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17102 Chauncey Kepford Ellyn R. Weiss, Esquire Judith Johnsrud Harmon & Weiss Environmental Coalition on Nuclear 1725 Eye Street, N. W., Suite 506 Power Washington, D. C. 20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholly Union of Concerned Scientists Marvin 2. Lewis 1725_ Eye Street, N. W., Suite 601 6504 Bradford Terrace Washington, D. C. 20006 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt ANGRY R. D. 5 '
245 West Philadelphia Street Coatesville, Pennsylvania 19320 York, Pennsylvania 17404 Attorney General of New Jersey Attention: Thomas J. Germine, Esquire Deputy Attorney General Division of Law - Room 316 1100 Raymond Boulevard Newark, New Jersey 07102 l
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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 (Three Mile Island Nuclear
) (Restart)
)
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the "Intervenor Response to Board Request For Evidence That Consideration of Control Room Operator Fatigue Is Appropriate," which was hand delivered tre to Licensee's representative by Norman Aamodt on March 10, 1981, were served upon the parties identified on the attached Service List by deposit in the United States mail, first class, postage prepaid, this 10th day of March, 1981.
/lS Y YEnMnu. s o q-Delissa A. Ridgway Dated: March 10, 1981 L
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