ML17139A353
| ML17139A353 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/20/1981 |
| From: | Stark R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17139A352 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8107220184 | |
| Download: ML17139A353 (7) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PENNSYLVANIA POWER
& LIGHT COMPANY
)
and ALLEGHENY ELECTRIC COOPERATIVES, INC.
(Susquehanna Steam Electric Station, Units 1 and 2)
Docket No. 50-387 O.L.
50-388 O.L.
AFFIDAVIT OF RICHARD M.
STARK I, Richard M. Stark, being duly sworn, dispose and state:
By whom are you employed and describe the work you perform?
A.
I am employed by the U.S. Nuclear Regulatory Commission as a
Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation.
A copy of re professional qualifications is attached.
g.
Have you read "Applicants'" Motion for Sumary Disposition of Contention 19," filed July 1, 1981, and the documents attached
- thereto, including the affidavit of Junius William Miliard?
A.
Yes.
8107220184 810720 PDR ADOCN, 05000387I G
PDR'
g.
Do you agree that Applicants'tatement of Material Facts shows that no genuine issue of material fact exists with regard to the possibility of the occurrence of a TMI-type accident at the Susquehanna facility?
A.
No.
Applicants'tatement only partially addresses the events which are necessary for a TMI-type accident.
g.
What events does Applicants'tatement fail to address?
A.
The NRC Staff describes a TMI-type accident as a small break loss of coolant accident (LOCA) which was not recognized by the plant operators, and which was complicated by equipment failures and human failures.
Applicants'tatement merely addressed the equipment failures which would be involved in a TMI-type accident at Susquehanna, i.e., small break LOCA and stuck relief valve.
Their statement failed to address human failures.
g.
What does the NRC Staff mean by "human failures" ?
A.
Human failures can occur both before and during a postulated TMI-type accident.
Human failures can include:
improper shift staffing and administration to deal with unusual situations;
inadequate emergency operating procedures; inadequate health physics organizations; incompatibility between operators and the systems that they operate; and inadequate operator training.
4~41 Richar M.
S gunua "m.c.~
LINDA )h. EYL R NPTARY PUBLIC 5 A E C" MPRYLAND hhy Commission Expires July 1, 19IR
RICHARD M. STARK PROFESSIONAL UALIFICATIONS I
am a Project Manager in Licensing Branch No. 2, Division of Licensing, U.S. Nuclear Regulatory Commission.
In this capacity, I am responsible for, the review of the nuclear reactor license application that is assigned to me.
This involves the planning, integration, and management of the efforts of reviewers from specialized areas to formulate NRC technical evaluations.
I am also the staff's primary contact with the applicants.
I develop recommendations for licensing actions and integrate the results of our reviews into environmental and safety evaluation reports.
I received a Bachelor of Science degree in Electric Engineering from the I
Carnegie Mellon University.
I also received a Master of Science degree in Nuclear Engineering from Carnegie Mellon University.
I am a Professional Engineer registered in the Commonwealth of Pennsylvania.
I have over seventeen years of professional experience in the nuclear field.
I worked for Westinghouse Electric Corporation and held positions in the nuclear field as a Reliability Engineer, System
- Engineer, Licensing Engineer and Project Engineer.
In addition I was an Engineering llanager for Stone and Webster Engineering Corporation responsible for all engineering on a nuclear project.
I am presently the NRC Project Manager for the Susquehanna Steam Electric Station license review.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
PENNSYLVANIA POWER AND LIGHT CO.
)
ALLEGHENY ELECTRIC COOPERATIVE, INC.
)')
(Susquehanna Steam Electric Station,
)
Units 1
and 2)
Docket Nos. 50-387 8
50-388 CERTIFICATE OF SERVICE I hereby certi fy that copies of "NRC STAFF
RESPONSE
OPPOSING APPLICANTS'OTION FOR
SUMMARY
DISPOSITION OF CONTENTION 19" and "NRC STAFF STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD (CONTENTION 19)" and "AFFIDAVIT OF RICHARD M. STARK" dated July 20,
- 1981, in the above-captioned proceeding, have been served on the following by deposit in the United States mail, or as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 20th day of July, 1981:
James P. Gleason, Chairman Administrative Judge 513 Gilmoure Drive Silver Spring, Maryland 20901 Mr. Glenn 0. Bright Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. Paul W.
Purdom Administrative Judge 245 Gulph Hills Road
- Radnor, Pennsylvania 19087 Jay Silberg, Esq.
Shaw, Pittman, Potts and Trowb> idge 1800 M Street, N.W.
Washington, D.C.
20036 Bryan A. Snapp, Esq.
Pennsylvania Power 8 Light Comp,ugly Two North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State
- College, Pennsylvania 16801 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection'epartment of Environmental Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Ms. Colleen Marsh Box 538A, RD<~4 Mountain Top, Pennsylvania 17120 Mr. Thomas J. Halligan Correspondent:
CAND P. 0.
Box 5 Scr'anton, Pennsylvania 18501
- Richard S.
- Salzman, Esq.,
- Chairman, Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Dr. Joh'n H. Buck, Administrative Judge Atomic. Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- f1r. Thomas S. Moore, Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 "Atomic Safety 5 Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 "Atomic Safety 8 Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTN:
Chief, Docketing 5 Service Branch Washington, D.C.
20555 Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.
P.O.
Box 1560 Wilkes-Barre, PA 18703 l1r. Robert M. Gallo Resident Inspector P.O.
Box 52 Shickshinny, Pennsylvania 18655 Robert W. Adler Dept. of Environmental Resources 505 Executive House P.O.
Box 2357 Harrisburg, Pennsylvania 17120 essica H. Laverty Counsel for NRC Staff