ML20049F885
| ML20049F885 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/30/1981 |
| From: | Capra R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20049E246 | List: |
| References | |
| NUDOCS 8110020420 | |
| Download: ML20049F885 (8) | |
Text
10/30/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEF_0RE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, ET AL
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear Station
)
Unit 1)
AFFIDAVIT OF ROBERT A. CAPRA I Robert A. Capra being duly sworn, depose and state that:
1.
I am an employee of the U.S. Nuclear Regulatory Comission (NRC). My present position is Technical Assistant to the Director, Division of Systems Integration within the Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached to this affidavit and is also bound into the record in the above captioned proceeding following Tr.15,835, 2.
Dr. Denwood F. Ross Jr., (then Director, Division of Systems Integration) and I testified at the hearing concerning questions raised by the Board and parties related to the testimony of Dale F. Thatcher (no longer employed with the NRC) on Sholly Contention 6a concerning the integrated control system (ICS) failure mode and effect analysis. My position as reflected in my testimr)ny is that in the April /May 1979 timeframe, the staff expressed concerns regarding the response of B&W-designed reactors to feedwater transients.
Since the staff had not per-formed a detailed review of the ICS, it was unsure of the role that the ICS might play in initiating or exacerbating feedwater transients. Therefore, the staff required that a failure mode and effect analysis (FMEA) of the system 8110020420 810930 PDR ADOCK 05000289 0
be performed.
Babcock and Wilcox (B&W) performed a reliability analysis (including an FMEA) that was endorsed by the licensee and submitted to the staff for review. The staff completed its review of the report (BAW-1564) through a technical assistance contract with Oak Ridge National Laboratory (ORNL). As a result of this review, both the staff and ORNL concluded that the ICS itself had a relatively low failure rate and did not appear to initiate a significant number of plant upsets. However, there were aspects of the plant control system and related components (mostly outside of the ICS) for which improvements should be investigated. B&W recommended actions aimed at improving system performance. These recommendations were transmitted to the licensee for action. Thus, no additional system upgrades beyond those identified in BAW-1564 were required of the licensee.
3.
At the time my testimony was given, I was not aware of the Memorandum from J. M. Allen (NRC Region I) to N. C. Moseley (NRC Region I) dated October 16, 1979,
Subject:
" Operation Team Recommendations-IE/TMI Unit 2 Investigation," (" Martin Report"). Hafever, I have examined the information in the Martin Report cited by intervar.or Sholly relevant to the matters about which I testified at the hearing, specifically, recommendation C.l.b.3, "ICS."
The recoamendation in the Martin Report is not significant with respect to my testimony particularly because:
(a) no technical basis is presented for the recommendation made; (b) the recommendation is not consistent with NRC philosophy of separation of control systems and safety or protection systems; and, (c) the ICS played no role in either initiating or exacerbating the accident at TMI-2.
Nevertheless, I have considered the Martin Report reconinendation and find that it does not affect my technical position as reflected in my testimony at the hearing for the reasons stated below.
Reconinendation C.l.b.3, of the Martin Report, has three subparts.
Each will be addressed separately.
S_ubpart 1:
" Provide the requirements for a safety-related ICS."
Response: A regulatory philosophy for the separation of protection and control systems was developed in the 1960s and early 1970s through interactions among the regulatory staff, the ACRS, the AEC and the industry. The interactions occurred primarily through development of industry standards such as IEEE-279,
" Criteria for Protection Systems for Nuclear Power Generating Stations," and the licensing reviews of early coninercial nuclear power plants. A nuclear power plant must satisfy utility requirements for the economic production of power.
Plant control systems were established to accomplish the desired operational characteristics for power production. To assure that safety limits were not exceeded should any system, including control systems, used for normal operation fail, various protective functions such as reactor trip and decay heat removal systems were established in the Commission regulations. Protection systems were provided to accomplish the protective functions. Thus, the philosophy was developed that protection systems were treated separately from control systems. Control systems are not classified as " safety-related" and do not have to meet safety-grade requircents. The staff has begun several specific actions to provide added assurance that the current licensing practices are adequate.
These include:
(a) Designation by the Commission of the " Safety Implications of Control Systems" as an Unresolved Safety Issue (USI A-47);
4 (b) A request by the staff that licensees of operating plants review the potential for and the consequences of several particular categories of control system failures; and, (c)
Increased emphasis in the staff reviews r.,f operating license applications on studies performed by the applicants and reactor vendors of particular categories of control system failures.
At the present time, the staff knows of no specific control system (including the ICS) failures or actions which would lead to unacceptable consequences.
However, as described above, a variety of efforts are continuing to detemine the potential :,afety consequences of control system failures. Should these reviews indicate that additional criteria for control system design are required or that specific problems require resolution, appropriate action will be taken for plants in the licensing process and for plants now in operation.
Subpart 2:
" Evaluate the continued operation of B&W plants without safety-related ICS."
Response: As discussed above, such an evaluation was perforned in the short term through the submission and review of the ICS reliability analysis. For, the longer tem, the staff has met with the Advisory Conrnittee on Reactor Safejuards (ACRS) to discuss:
(a) past practice with respect to staff review of control systems; (b) staff actions currently in progress or planned for the near future on control systems; and, (c) questions on the staff spproach to the review of control systems.
-S-As a result of this review, the ACRS recomended neither shutdown nor derating of operating plants. The Comittee did, however, recomend increased priority on generic, systematic studies of control system failures through USI A-47, " Safety Implications of Control Systems."*
Subpart 3:
" Consider extra shift personnel assignments and procedural controls to provide ICS backup during loss of power conditions and/or loss i
of the ICS situations."
Response: This subpart of the recommendation was adequately considered in the development of TMI Action Plan (NUREG-0660) item I.A.3.
The Martin Report is referenced on page I.A.1-5 of NUREG-0660.
In addition, as pointed out in the Sholly motion, NUREG-0667, " Transient Response of Babcock &
Wilcox-Designed Reactors) recommendation 12 reads "A qualified Instrumentation
& Control Technician (I&CT) should be provided on a round-the-clock basis at all operating B&W plants." This recomendation was not implemented based upon the evaluation of NUREG-0667 recomendations perfonned by the Division of Safety Technology (DST). This evaluation is documented in a Memorandum from R. J. Mattson (DST) to H. R. Denton (NRR) dated August 8,1980, i
Subject:
" Review of Final Report of the B&W Reactor Transient Response Task Force (NUREG-0667)." The basis for not requiring this action by licensees is detailed in the memorandum. Although DST concluded that there were advantages for a utility to have this round-the-clock coverage, it should I
not be an NRC requirement since other actions had and were being implemented to assure that operators had sufficient mans to determine the condition of the plant during an abnormal condition caused by an ICS/NNI failure.
l l
- Letter from J. Carson Mark (ACRS) to Chainnan J. M. Hendrie, dated May 12, 1981,
Subject:
" Response to Inquiry Concerning the Safety Implications of Control Systems."
t These actions were the development and implementation of emergency procedures that address loss of ICS/NNI and the eventual installation of a plant safety-parameter display console (Action Plan item I.D.2).
4.
In summary, my direct testimony on Sholly Contention 6a would be unaffected by the Operations Team reconinendation of the Martin Report.
The above statements and opinions are true and correct to the best of my personal knowledge and belief.
Y$ 0p J
Robert A. Capra i
Subscribed and sworn to before me this / *- day of September,1981.
k* A $][3
~:
n Judy L. Putts, Notary Public My Commission Exnires: July 1,1982
4 Robert A. Capra STATEMENT OF PROFESSIONAL QUALIFICATIONS 1
i Since June 1980 I have served as Technical Assistant to the Director, 4
Division of Systems Integration, Office of Nuclear Reactor Regulation, j
i U".S. Nuclear Regulatory Comission (NRC).
In this capacity I work for the Division Director on various technical and administrative matters associated with review and regulation of operating nuclear power plants i
i and plants under review for operating licenses.
i I enlisted in the United States Navy in July 1964 and served in'that capacity for three years. During that time my duties included attending 2
the Enlisted Naval Nuclear Power School, Mare Island, California followed by subsequent study and qualification as a reactor operator and staff instructor on the Navy's "D1G" reactor located in West Milton,New York.
Following my enlistment, I attended the United States Naval Academy where
~
l I graduated in June 1971 with a Bachelor of Science degree in Marine Eng-i ineering and was commissioned as a line officer in the United States Navy.
l Additional graduate level studies in nuclear reactor theory, thermodynamics, l
electrical engineering, health physics and other related engineering fields were completed in 1972 at the Officer Naval Nuclear Power School, Bainbridge, Maryland.
I subsequently returned to West Milton, New York where I studied I
and qualified as Engineering Officer of the Watch on the Navy's "D1G" reactor.
From 1973 to'1976, I served aboard an operating nuclear. submarine, during which time my duties included standing watch as Engineering Officer of the Watch and directing, training and supervising personnel under my supervision in the operatjon, maintenance and repair of various equipment and systems primarily associated with the ship's nuclear reactor.
During this period my assignments included supervision of the Operation Department, Electrical Division, Reactor Controls Division, Main Propulsion Division and the Chemistry and Radiological Cont 01 personnel.
In addition, I qualified as Chief Engineer for the supervision of operation and maintenance of Naval Nuclear Propulsion Plants.
2-
=
a From 1976 to 1978, I was assigned as a Company Officer a',the United States Naval Academy where my duties included supervising, directing and evaluating, the training and activities of 130 officer candidat s (midshipmen).
I joined the NRC staff in July 1978, where I served a; a Licensing Project Manager in the Division of Project Management.
In this' capacity, I coordinated the safety review of one operating license application (South Texas 1 and 2),
two construction permit applications (New Haven 1 and 2 and Haven, Unit 1) and served as the Project Manager for two plantsunder construction (North Anna 3 and 4).
In addition, I served as the Licensing Topical Report Manager for General Electric Topical Reports.
In June 1979, following the accident at Three tlile Island, Unit 2, I joined the Bulletins and Orders Task Force (B&OTF) and served as the Project Manager for the B&W Operating Reactors.
In this capacity. I coordinated and established priorities for the work being done by the Task Force which was associated with the B&W-designed plants.
I coordinated the scope and schedule of the work required by the B&W licensees and served es the principal-liaiscr between the Task Force, the licensees and the B&W Owners' Group. During this period, I served as editor of NUREG-0565 and NUREG-0667 and authored the B&W section of the B&OTF Final Report, NUREG-0645.
I served with the Task Force until I was assigned to my present position in June 1980.
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