ML20049G096
| ML20049G096 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/30/1981 |
| From: | Danielle Sullivan NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20049E246 | List: |
| References | |
| NUDOCS 8110020430 | |
| Download: ML20049G096 (2) | |
Text
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
i In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL )
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear Station,)
Unit 1)
)
AFFIDAVIT OF DONALD F. SULLIVAN I, Donald F. Sullivan, being duly sworn, do depose and state:
1.
I am employed as a Senior Nuclear Engineer by the Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission.
I am currently serving as Acting Branch Chief, Electrical Engineering Branch, Office of Nuclear Regulatory Research. A copy of my professional qualifications was bound into the record in the above-captioned proceeding following Tr. 6602.
l 2.
I testified at the hearing in response to UCS Contention 10 concerning completion of a safety function. My position as reflected in mv testimony is that I do not agree that the design of the protectioi.
system at TMI-1 violates Section 4.16 of IEEE 279 as incorporated i
l in 10 CFR 50.55a(h), or that the design must be modified so that no operator action can prevent the completion of a safety function once initiated.
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3.
I was not aware of the memorandum from J. M. Allan, NRC Region I, to N. C. Moseley, dated October 16, 1979, Sub, ject: Operations Team Recommendations - IE/TMI Unit 2 Investigation (" Martin Report").
In fact, I did not become aware of the report until approximately 10 days ago. However, I have examined the infomation in the Martin Report relevant to matters about which I testified at the hearing. The recommendations of the Martin Report include the following:
" Provide a ' lock-in' feature on the ESFAS such to prevent inappropriate operator defeat of the ESF equipment." The infomation, including the cited recommendation, is not significant with respect ta my testimony because (a) its meaning is not clear, and (b) no technical basis is given for the recommendation made.
I have, nevertheless, considered the relevant Martin Report information, including the cited recomendation, and find that it does not affect my technical position as reflected in the testimony at the h' earing.
The above statements and opinions are true and correct to the best of my personal knowledge and belief.
l N
Subscribed and sworn to before me this JO dayofvliLN'ut/itt, /N/,
h d c. h t u il s a ' E ~
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