ML19350A308

Affidavit Re Ucs Contention 10 Asserting That Section 4.16 of IEEE Std 279-1968 Requires That Safety Sys Must Be Designed So That No Operator Action Can Prevent Completion of Safety Function Once Initiated

ML19350A308
Person / Time
Site:	Three Mile Island
Issue date:	02/26/1981
From:	Patterson E METROPOLITAN EDISON CO.
To:
Shared Package
ML19350A307	List: ML19350A306 ML19350A308
References
NUDOCS 8103130452
Download: ML19350A308 (3)

Text

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1 O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

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 )

AFFIDAVIT OF ELMER S. PATTERSON City of Lynchburg )

SS Commonwealth of Virginia )

Elmer S. Patterson, being duly sworn according to law deposes and says as follows:

1. I have reviewed the trar. cript of the captioned croceedina for November 25, 1980, pages 6712 througn 6788, containing additional testimony oy Mr.

Robert D. Pollard on behalf of the Union of Concerned Scientists and Mr.

Donald F. Sullivan of the NRC staff relative to UCS Contention -10.

1

2. UCS Contention' 10 asserts that Section 4.16 of IEEE Std. 279-1968 requires that safety systems must be designed so that no operator action can prevent the completion of a safety function once initiated. Mr. Pollard in the supplementary testimony cited in Paragraph I has expressed the opinion that

.IEEE Std. 603-1977 should be utilized to determine the cor ect meanina and

- historical intent of IEEE 279.

810s.1gg Q

3. IEEE 603-1977 was a Trial-Use document wnich has never been tes ec oy usage or sanctioned in the nuclear regulatory process. Adcitionally, IEEE 603-1977 has now been replaced oy IEEE Std. 603-19EO. IEEE 603-1930 does not sucercede or enange the requirements of IEEE 279 and its nuclear regulatory applicasility, if any, has not been determined.

4 Nevertheless, I personally cannot accept Mr. Pollard's interpretaticn of Section 4.4 of IEEE 603-1977. I was an active . member of the Work Group which authored IEEE 603-1977, and of the oversignt IEEE subcommittee and parent committee, during the four-year period of develooeent of the standard.

5. The last-sentence of Section 4.4 of IEEE 603-1977 was incorporated at my initiative to make it clear that Section 4.4 was not to be interpreted as Mr. Pollard has in his testimony:

"This requirement shall not preclude the use of ecuipment protective devices or the crovision for nose deliberate operator interventions which are identified in 3.10 of the design basis."

6. As stated in Paragraph 4, I was also on the oversight IEEE subcomittee for IEEE 603 and agree with Mr. Sullivan (Tr. 6743-67c9) that the interpretation fostered by Mr. Pollard was not an issue durinc the acproval of the standard. I believe that the understanding and intercretation of

IEEE 603 between Mr. Sullivan and myself is typical of the subcommittee and parent committee. If I had had any cause to suspect that these organizations intended IEEE 603 to be acclied as contended by .v r . Pollard I would have emphatically objected at tnat time, and balloted against the standard at each level (three) of approval and assured that the position was well ventilated.

7. Frankly, I felt during the final preparation and approval of IEEE 603, as I do today, that the language is clear and could not reasonably be interpreted to require, as mandatory, that system desian should prevent operator intervention prior to completion of a safety action.

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Elmer S. Patterson Subscribed and sworn to before me this - day of

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Notary Public

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My commission expires on .f ,

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