ML19297C792

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Forwards Testimony Establishing Definition of Terms Important to Safety & safety-grade. Definition of Term safety-related Not Fully Resolved.Consistent Usage of Terms Should Be Emphasized
ML19297C792
Person / Time
Site: Crane 
Issue date: 10/30/1980
From: Ross D
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
Shared Package
ML19297C789 List:
References
NUDOCS 8101080037
Download: ML19297C792 (3)


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% j DCT 3 0 880 MEMORANDUM FOR: All DSI Personnel Denwood F. Ross, Jr., Director, Division of Systems FROM:

Integration, NRR SAFETY TERMINOLOGY USED IN TMI-l RESTART HEARING TESTIMONY

SUBJECT:

One contention by intervenors in the TMI-1 Restart Hearing would require that all non-safety components that could cause or aggravate an accident, or that could be called upon to mitigate the consequences of an accident, should be Specific examples focused on by the intervenors in this made safety-grade.

regard, include the PORV and block valves, pressurizer heaters, and reactor coolant pumps, in view of the roles played by those components in the TMI-2 In addressing this issue, it was accident sequence and recovery process.

necessary to focus on the definition, application, and common-usage of the teminologies employed by the staff in this regard.

The attached testimony establishes the definition for two of the most frequently used tems of this kind, i.e., "important to safety" and " safety-grade."

It should be noted that another frequently used tenn, i.e., " safety-related,"

is not treated in the attached testimony. Office of Standards Development has prepared a Commission Paper that is intended to resolve the definition of that The thrust of the OSD effort is to establish that the tenns " safety-term.

related" and "important to safety." as they are defined and used in the regu-lations, are synonymous (at least in the context of appitcation of the quality At this point, however, assurance criteria of Appendix-B to-10 CFR Part 50).

the definition of the tern " safety-related" is not yet fully resolved; and, because the OSD-effort involves.a proposed change _to the language of Appendix B, the Commission will have the final word in that regard.

To the extent that definitions for commonly-used safety terminologies have been established (as in the attached testimony), our goal should be consistency in More to the point, in their usage and application in all of our activities.

the context of immediate concern, I expect all DSI personnel involved in the TMI-1 Restart Hearing to give particular emphasis to consistent usage and application of-the-terms "important to safety" and " safety-grade"-in accordance with the definitions established in the attached testimony. _ __

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<R Denwood'F Ross, Jr., Dir'ector )

Division of Systems Integration Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page 8101080037

OCT 3 c 1980 H. R. Denton, DIR, NRR cc:

R. B. Minogue, DIR, 050 V. Stello, DIR, IE H. Shapar, DIR, ELD All NRR Division Directors H. Sflyer, DOL S. Richardson, OSD J. M. Cutchtn, IV, ELD T. F. Dorian, ELD

ENCLOSURE ELO

SUMMARY

OUTLINE

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This testimony of James H. Conran contains the NRC Staff's response to UCS

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Contention 14.

The purpose of this testimony is to demonstrate that, contrary to the assertions made in the contention, all systems or components of the core cooling system which can either cause or aggravate an accident or can be called upon to mitigate [the consequences of] an accident need not be required to meet safety-grade design criteria. '

Conclusions to be drawn from this testimony:

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-- NRC regulations do not require that all components and systems that are classified as "important to safety" be designated safety-grade" and

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designed and qualified to very high standards.

-- Only those systems and components required to perform safety functions s

are designated safety-grade.

- Those critical safety functions are identified'in SectiorLIII(c) of Apper. dix A to-10 C.F.R.100-

- Those systems and components which must be safety-grade are identified in Regulatory Guide 1.29.

-- That failure or off-normal operation of certain non-safety components and systems could cause or aggravate an accident or that certain non-safety components and systems could be called upon to mitigate the consequences of.an. accident does,not mean that those components and systems must be classified, designed and qualified as safety-grade.

-- Whether a non-safety system should be upgraded to safety-grade is determined ~

by applying certain decision criteria set forth in the testimony.

-- Application of those decision criteria indicates that none of the non-safety systems or components which contributed adversely to or were called upon to mitigate the consequences of the TMI-2 accident need be classified as safety grade.

-- The Staff is reassessing the appropriateness of current non-safety

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classifications of systems and components in view of the lessons learned from the TMI-2 accident.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of Decket Nc. 50-289 METRC?OLITAN EDISCN COMPANY,

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ET AL (Three Mile Island Nuclear

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Station Unit 1)

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NRC STAFF TESTIMPNY OF JAMES H. CONRAN RELATIVE TO CLASSIFICATION OF SYSTEMS AND COMPONENTS AS IMPORTANT TO SAFETY (UCS CONTENT!CN 14)

Please state your name and your position with the NRC.

Q.1 I am an employee of the U. S. Nuclear Regulatory A.

My name is James H. Conran.

Cormiission, assigned to the Systems Interaction Branch in the Division of Systems Integration, Office of Nuclear Regulatory Regulation.

0.2 Have you prepared a statement of professional qualifications?

A copy of that statement is attached to this testimony.

A.

Yes.

Please state the nature of the responsibilities that you have had with

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Q.2 rescect to Three Mile Island Nuclear Station Unit l_(TMI-1).

A.

Prior to the March 28, 1979 accident at Unit 2, I had no involvement with Following the accident at Unit 2. I was assigned either of the TMI units.

for several months to the task of monitoring for_NRR the ACRS proceedings s of recorriendations made by the DUPLICATE DOCUMENT Entire document previously entered into system under:

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