ML20049G167

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Affidavit of Jh Conran That 791016 Operations Team Recommendations-IE/TMI Unit 2 Investigation Would Not Change Testimony on Ucs Contention 14.Notices of Appearances & Certificate of Svc Encl
ML20049G167
Person / Time
Site: Crane Constellation icon.png
Issue date: 09/30/1981
From: Conran J
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20049E246 List:
References
NUDOCS 8110020433
Download: ML20049G167 (7)


Text

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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS5 ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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METROPOLITAN EDIS0N COMPANY, ET AL )

Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear Station,)

Unit 1)

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AFFIDAVIT OF JAMES H. CONRAN I, James H. Conran, being duly sworn, do depose and state:

1.

I am employed as a Principal Systems Engineer by the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.

A copy of my professional qualifications was bound into the re-4 cord in the above proceeding following Tr. 8372, 2.

I testified at the hearing concerning UCS Contention No.14 which addressed the issue of safety classification of reactor plant equipment and corresponding design criteria to be applied.

My position as reflected in my testimony is as follows:

a)

In general, although a component or system may be classi-fied as "important to safety" (in accordance with the definition of that term in 1GCFR50 Appendix A), it need not be designed to " safety-grade" standards unless it is required for certain critical safety functions that are identified-ex-plicity in 10CFR100 Appendix A.

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2 b) With regard to the TMI-2 accident specifically, the failure of non-safety components did contribute to the accident, and non-safety components were used in recovering from the accident. But detailed analyses performed by the NSSS vendor and reviewed by the NRR staff indicate that if installed safety systems had not been turned off by operators:

1) The installed safety systems would have accommodated the effects of the non-safety failures that occurred, and
11) operators would not have had to rely on non-safety systems (after core damage and flow blockage resulted from turning off installed safety systems) to reach cold shutdown The non-safety systems / components involved, then, need not be considered required for assurance of critical safety func tions. What is required is added assurance that operators will not improperly interfere with the operation of installed safety systems in future circumstances where their functioning is required (including response to non-safety component fail ure). A number of measures have been taken to provide l

l the added assurance required in this regard.

3.

With regard to the recommendations of the IE Operations Team, which are pertinent to the issues involved in UCS Contention No.14, to the best of my knowledge 1 was not aware of their existence until l

very recent1/ when I was informed of the intervenor's motions to l

reopen the TMI-l hearing record. Even if I had been aware earlier I

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of thnse recommendations, it would not have altered my testi-mony (written or oral) on Contention No.14 for the following reasons.

I have examined the information in the IE Operations Team report, and I find that it contains no significant in-formation or argumentation beyond that already considered in the formulation of my testimony on UCS Contention No.14. The issues involved were not raised and considered solely by the IE Operations Team. The Lessons Learned Task Force, of which I was a member, considered whether or not it was necessary to upgrade to full safety grade the non-safety components involved in the TMI-2 accident sequence and recovery. The conclusion of the Task Force was that detailed analyses should be done as a basis for determination. Such analyses were performed by the NSSS vendor and were reviewed by the NRR staff; the results in-dicated that upgrading to full safety grade was not required.

So even if I had been aware of the recommendations of the IE Operations Team, that would not have altered my testimony on UCS Contention No.14 because I relied on the results of the detailed analyses described above.

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The above statements are true and correct to the best of my personal knowledge and belief.

wA pmes H. conran Subscribed and sworn to before me thisd8 day of d c./ff/

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4<bYLC EN COMMfS N EXP!RES ' ULY I'.1982 J

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

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METROPOLITAN EDIS0N COMPANY, ET AL.

Docket No. 50-289

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(Restart)

(Three Mile Island, Unit 1)

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NOTICE OF APPEARANCE OF MARY E. WAGNER Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.

In accorda. ace with 92.713(b),

10 C.F.R. Part 2, the following information is provided:

Name:

- Mary E. Wagner Address:

- U.S. Nuclear Regulatory Cmmission Office of the Executive Legal Director Washington, D.C.

20555 Telephone Number:

- (301) 492-8659 Admission:

- New York Court of Appeals

- United States District Court for the Southern District of New York

- United States District Court for the j

Eastern District of New York

- District of Columbia Court of Appeals Name of Party:

- NRC Staff U.S. Nuclear Regulatory Cmmission Washington, D.C.

20555 y

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fL Q Mary E. Wagner

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Counsel f or NRC Stiff Date at Bethesda, Maryland this 30th day of Septaber,1981

UNITED STATES OF AMERICA HUCLEAR REGULATORY COMMISS.;

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, ET AL.

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Docket No.

50-289

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(Restart)

(Three Mile Island, Unit 1)

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NOTICE OF APPUARANCE OF EDWARD G. KETCHEN Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.

In accordance with 92.713(b),

10 C.F.P,. Part 2, the following information is provided:

Name:

Edward G. Ketchen Address:

U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, D.C.

20555 Telephone Number:

(301) 492-7502 Admission:

Supreme Court, State of Tennessee Maryland Court of Appeals l

District of Columbia Court of-Appeals l

Name of Party:

NRC Staff l

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 t

h.

51w Edward G. Ketchen Counsel for NRC Staff l

Date at Bethesda, Maryland j

this 30th day of September,1981 l

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I f

UNITED STATES OF AMERICA NUCl. EAR REGULATORY COMMISSION BEFORE Tt 2 ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, ET AL.

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

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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC RESPONSE IN OPPOSITION TO SHOLLY AND UCS MOTIONS TO RE0 PEN THE RECORD AND FOR FURTHER RELIEF," " NOTICE OF APPEARANCE OF EDWARD G. KETCHEN" and " NOTICE OF APPEARANCE OF MARY E. WAGNER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit ia the Nuclear Regulatory Commission's internal mail system, this 30th day of S1ptember,1981 :

  • Stephen F. Eilperin, Chairman Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board Panel 5000 Hermitage Drive U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27612 Washington, DC 20555 George F. Trowbridge, Esq.
  • 0r. John H. Buck Shaw, Pittman, Potts & Trowbridge Atomic Safety & Li ensing Appeal 1800 M Street, N.W.

l Board Panel Washington, DC 20006 U.S. Nuclear Regulatory Comission Wasnington, DC 20555 Xarin W. Carter, Esq.

505 Executive M.use

  • Christine N. Kohl P. O. Box 2357 Atomic Safety & Licensing Appeal Harrisburg, Pennsylvanic 17120 Board Panel l

U.S. Nuclear Regulatory Commission Honordble Mark Cohen i

Washington, DC 20555 512 0-3 Mair. Capital Building l

Harrisburg, PA 17120

  • Ivan W. Smith, Esq.

l Administrative Judge l

Atomic Safety & Licen,ing Board Panel Ms. Marjorie Aamodt U.S. Nuclear Regulatory Commission R.D. #5 Washington, DC 20555 Coatesville, PA 19320 Dr. Walter H. Jordan Mr. Thomas Gerusky Administrative Judge Bureau of Radiation Protection 881 W. Outer Drive Dept. of Environmental Resources i

Oak Ridge Tennessee 37830 F. O. Box 2063 l

Harrisburg, PA 17120

1 4 4 Mr. Marvin I. Lewis 6504 Bradford Terrace

  • Atomic Safety and Licensing Appeal Board Philadelphia, PA 19149 U.S. Nuclear Regulatory Commission Washington, DC 20555 Metropolitan Edison Company ATTN:

J. G. Herbein, Vice President

  • Atomic Safety and Licensing Board Panel P. O. Box 542 U.S. Nuclear Regulatcry Commission Reading, PA 19603 Washington, DC 20555 Ms. Jane Lee
  • Secretary R.D. 3; Box 3521 U.S. Nuclear Regulatory Commission Etters, PA 17319 ATTN: Chief, Docketing & Service Br.

Washington, DC 20555 Walter W. Cohen, Consumer Advocate Department of Justice William S. Jordan, III, Esq.

Strawberry Square,14th Floor Harmon & Weiss Harrisburg, PA 17127 1725 I Street, N.W.

Suite 506 Thomas J. Germine Washington, DC 20006 Deputy Attorney General Division of Law - Room 316 John Levin Esq.

1100 Raymond Boulevard Pennsylvania Public Utilities Comm.

Newark, New Jersey 07102 Box 3265 Harrisburg, PA 17120 Allen R. Carter, Chairman Joint Legislative Committee on Energy Jordan D. Cunningham, Esq.

Post Office Box 142 Fox, Farr and Cunningham Suite 513 2320 North 2nd Street Senate Gressette Building Harrisburg, PA 17110 Columbia, South Carolina 29202 Louise Bradfard Robert y. Pollard Three Mile Island Alert 609 Montpelier Street 315 Peffer Street Baltimore, Maryland 21218 Harrisburg, PA 17102 Chauncey Kepford Ms. Ellyn R. Weiss Judith Johnsrud Harmon & Weiss Environmental Coalition on Nuclear Power 1725 I Street, N.W.

433 Orlando Avenue Suite 506 State College, PA 16801 Washington, DC 20006 Ms. Frieda Berryhill, Chairman Mr. Steven C. Sholly Coalition for Nuclear Power PlarL Union of Concerned Scientists Postponement 1725 I Street, N.W.

2610 Grendon Drive Suite 601 Wilmington, Delaware 19808 Washington, DC 20006 Gail Phelps ANGRY 245 W. Philadelphia Street

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d York, Pennsylvania 17401 Edward G. Ket'chen Counsel for NRC Staff

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