ML19309C021

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Response to Chesapeake Energy Alliance Interrogatory 12-16 Re Bw Analysis of Integrated Control Sys.Area of Concern Re Multiple Failure Is Relatively Insignificant.Affidavit & Certificate of Svc Encl
ML19309C021
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/31/1980
From: Singer L
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Chesapeake Energy Alliance
Shared Package
ML19309C022 List:
References
NUDOCS 8004080045
Download: ML19309C021 (7)


Text

a NRC 03/31/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDIS0N COMPANY,

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Docket No. 50-289 ET AL.

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l

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(Three Mile Island, Unit 1)

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NRC STAFF RESPONSE TO CEA SECOND SUPPLEMENT TO ITS INTERROGATORIES TO NRC STAFF Enclosed is the answer to CEA interrogatory 12-16. The interrogatory has been restated and a response provided. The affidavit verifying the answer of the NRC Staff member who answered the interrogatories is attached, along with his personal qualifications statement.

Respectfully submitted,

/

/tlX{ //{ N..i }1}'t L Lisa N. Singer Counsel for NRC Staff Dated at Bethesda, Maryland, this 31st day of March, 1980.

8004080 9

12-16 Answer the interrogatory posed to Licensee (LIC) as 12-14 in CEA: DIS:LIC at 6-7 except that whenever 12-14 (LIC) refers to

'LIC', 'NRC' shall be substituted.

Response

The two questions posed by Oak Ridge were intended to help clarify the bases for the choice of a failure mode and effects analysis (FMEA) perforned by B & W as a part of their analysis of the integrated control system (ICS).

It was recognized that the FMEA may have shortcomings. However, it was shown in the " Operating Experience" section (the other section of the B & W Report - BAW 1564) that the ICS hardware failures (single or multiple) have not led to a significant number of plant upsets (i.e. reactor trips). Oak Ridge has concurred in this conclusion (see " Report Review:

Integrated Control System Reliability Analysis" performed by Oak Ridge National Laboratory).

Therefore, although fault tree analysis (FTA) may have been a better technique for addressing such " multiple failure" concerns, the analysis of the operating experience at B & W plants indicates that this area of concern is relatively insignificant.

There have been no fault tree analyses that have been conducted or commissioned by or for NRC to specifically " remedy the omission of multiple failure considerations."

. The basis for not conducting such an analysis is that the operating experience indicates that ICS hardware performance has not led to a significant number of reactor trips. There is therefore little to gain in overall plant performance (i.e., reducing challenges to the plant protection systems) by trying to improve this area.

Lack of available time is not explicitly cited as the justification for not performing such an analysis, however such justification is implicit in any judgment regarding

" significance." Those items considered insignificant receive relatively low priority with respect to time available and may in fact never be pursued.

In this case, we believe that conducting such an analysis at this time for the purpose of addressing this area of concern is not warranted based on the results of other analysis cited.

9 k

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMf1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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METROPOLITAN EDIS0N COMPANY, et al.

Docket No. 50-289 (Three Mile Island, Unit 1)

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AFFIDAVIT OF DALE F. THATCHER I, Dale F. Thatcher, being duly sworn, do depose and state:

1.

I am a reactor engineer in the Nuclear Regulatory Commission Staff's Instrumentation and Control Systems Branch.

I am responsible for the review and evaluation of the instrumentation and control systems of nuclear power generating stations.

2.

The answers to Chesapeake Energy Alliance (CEA) Interrogatory 12-16 were prepared by me.

I certify that the answers given are true and accurate to the best of iny knowledge.

W

. Dale F. Thatch 6r

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Subscribed and sworn to before me this 27thday of March, 1980.

M.lbtf 6cL 4

t hotap) Public

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My Commission Expires:

July 1, 1982

DALE F. THATCHER

,j PROFESSIONAL QUALIFICATIONS INSTRUMENTATION & CONTROL SYSTEMS BRANCH DIVISION OF SYSTEMS SAFETY I am a Senior Reactor Engineer in the Instrumentation and Control Systems Branch, Division of Systems Safety, Nuclear Regulatory Commission.

From May to December 1979, I was assigned to the Bulletins and Orders T6sk Force as a technical reviewer in the area of instrumentation and control.

Just prior to this assignment I was a member of the NRR team which aided in the Three Mile Island Recovery Operation.

In the ICSB, my primary responsibility is to perform technical reviews of the design, fabrication, and operation of instrumentation and control systems for nuclear power plants. This review encompasses evaluation of applicant's safety analysis reports, generic reports and other related information on the instrumentation and control designs.

I graduated from Lehigh University with a Bachelor of Science Degree in Electrical Engineering in June 1971.

From my graduation in June 1971 until my employment at the Commission ~, I was an Instrumentation Engineer with Gilbert Associates, Inc., an Architect-Engineering company located in Reading, Pennsylvania. My responsibilities included the design and evaluation of various instrumentation and control systems including primarily the areas of reactor protection systems and other safety systems for various domestic nuclear power plants.

I joined the Regulatory staff of the Atomic Energy Commission in March 1974 as a Reactor Engineer. Since then, I have participated in the review of instrumentation control and electrical systems of numerous nuclear power stations and standard plant designs.

In addition, I have participated in the formulation of related standards and regulatory guides.

I am a member of the Institute of Electrical and Electronics Engincers (IEEE) and have participated in the development of IEEE Standard 379-1977, "IEEE Standard Application of the Single Failure Criterion to Nuclear Power Generating Station Class IE Systems" and other proposed standards.

UNITED STATES OF AMERICA NUCLEAR REG'JLATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

In the Matter of METROPOLITAN EDISON COMPANY,

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Docket l'o. 50-289 ET AL.

(Three Mile Island, Unit 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO CEA SECOND SUPPLEMENT TO ITS INTERR0GATORIES TO NRC STAFF" (with enclosure) in the above-captioned proceeding have been served on the followino by deposit in the United Stiftes mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Comission internal mail systert, this 31st day of March,1980:

  • Ivan W. Smith, Esq.

Ellvn Weiss, Esq.

Atomic Safety & Licensing Board Panel Sheldon, Har. Ton, Roisman & Weiss U.S. Nuclear Regulatory Commission he 5 Washington, D. C.

20555 Washington, D.C.

20006 o

Dr. Walter H. Jordan Mr. Steven C. Sholly 881 W. Outer Drive 304 South Market Street Oak Ridge, Tennessee 37830 Mechanicsburg, Pennsylvania 17055 Dr. Linda W. Little 5000 Hermitage Drive Mr. Thomas Gerusky Raleigh, North Carolina 27612 Bureau of Radiation Protection Department of Environmental Resources George F. Trowbridge, Esq.

P.O. Box 2063 Shaw, Pittran, Potts & Trowbridge Harrisburg, Pennsylvania 17120 1800 M Street, N.W.

Washington, D. C.

20006 Mr. Marvin I. Lewis 6504 Bradford Terrace Karin W. Carter, Esq.

Philadelphia, Pennsylvania 19149 505 Executive House P. O. Box 2357 Metropolitan Edison Company Harrisburg, Pennsylvania 17120 Attn:

J. G. Herbein, Vice President P.O. Box 542 Reading, Pennsylvania 19603 Honorable Mark Cohen 512 E-3 Main Capital Building Ms. Jane Lee Harrisburg, Pennsylvania 17120 R.D. 3; Box 3521 Etters, Pennsylvania 17319

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6-

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Walter W. Cohen, Consumer Advocate Holly S. Keck Department of Justice Anti-fluclear Group Representing Strawberry Square,14th Floor York Harrisburg, Pennsylvania 17127 245 W. Philadelphia Street York, Pennsylvania 17404 tis. Karen Sheldon Sheldon, Harmon, Roisman a Weiss John Levin, Esq.

1725 I Street,fl.W.

Pennsylvania Public Utilities Co=.

Suite 506 Box 3265 Washington, DC 20006 Harrisburg, Pennsylvania 17120 Ms. Frieda Berryhill, Chatrnan Jordan D. Cunningham, Esq.

Coalition for iluclear Power Fox, Farr and Cunningham Plant Postponenent 2320 fiorth 2nd Street 2610 Grendon Drive Harrisburg, Pennsylvania 17110 liflmington, Delaware 19898 Ms.KathyMcdaughin Three Mile Island Alert, Inc.

  • Atomic Safety and Licensing Appeal Board 23 South 21st Street U.S. fluclear Regulatory Commission Harrisburg, Pennsylvania 17104 Washington, D. C.

20555 S

a orie M. Aamodt

  • Atomic Safety and Licensing Board Panel f"p U.S. Nuc1cer Regulatory Commission Coaf.esville, Pennsylvania 19320 Washington, D. C.

20555 Senator Allen R. Carter

  • Docketing and Service Section I

i" k'a i$i t

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5 e islative Comnittee on Ener:.

Post Office Box 142 Suite 513 Senate Gressette Building Robert O. Pollard Columbia, SC 29292 609 Montpelier Street Baltimore, Maryland 21218 Chauncey Kepford Judith H. Johnsrud Environmental Coalition on l'uclear Power 433 Orlando Avenue State College, Pcnnsylvania.16801 U M l. h ri m Lisa N. Singer

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Counsel for NRC Staff e

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