ML20079J179

Affidavit of Rd Pollard Re Emergency Feedwater Sys Flow Instrumentation.Design Does Not Comply W/Nrc Rules.Operation Would Pose Undue Risk to Health & Safety of Public. Certificate of Svc Encl

ML20079J179
Person / Time
Site:	Three Mile Island
Issue date:	01/20/1984
From:	Pollard R UNION OF CONCERNED SCIENTISTS
To:
Shared Package
ML20079J135	List: ML20079J133 ML20079J149 ML20079J179
References
NUDOCS 8401240239
Download: ML20079J179 (14)

Text

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DOCKETED US'lRC UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION ,84 JAN 23 Pi2:53 crr- cr m: r AFFIDAVIT OF ROBERT D. POLLARD i0~' t I, Robert D. Pollard, hereby make my affidavit as follows:

Since 1976, I have been employed in the Washington, D.C. office of the Union of Concerned Scientists (UCS) as a nuclear safety engineer.

My formal education in nuclear design began in May, 1959, when I was selected to serve as an electronics technician in the nuclear power program of the United States Navy. After completing the required training, I became an instructor responsible for teaching naval personnel both the theoretical and practical aspects of operation, maintenance and repair for nuclear propulsion plants. From February,1964, to April,1965, I served as the senior reactor operator, supervising the reactor control division aboard the U.S.S. Sargo, a

, nuclear-powered submarine. In 1965, I was honorably discharged from the U.S.

Navy, and attended Syracuse University, where I received the degree of Bachelor of Science magna cum laude in Electrical Engineering in June,1!'59.

In July,1969, I was hired by the United States Atomic Energy Comission

( AEC) and continued as a technical expert with the AEC and its successor, the United States Nuclear Regulatory Commission (NRC), until February, 1976.

After joining the AEC, I studied advanced electrical and nuclear engineering at the Graduate School of the University of New Mexico in Albuquerque. I subsequently advanced to the positions of Reactor Enginner (Instrumentation) and Project Manager with AEC/NRC. As a Reactor Engineer, I was primarily 8401240239 840120 PDR ADOCK 05000289 9 PDR

responsible for performing detailed technical reviews analyzing and evaluating the adequacy of the design of reactor protection systems, control systems and emergency electrical power systems in proposed nuclear facilities. In September,1974, I was promoted to the position of Project Manager and became

- responsible for planning and coordinating all aspects of the design and safety

reviews .of applications for licenses to construct and operate 3everal commercial nuclear power pl ants. Attached are copies of the NRC's "j ob descriptions" for the positions of Reactor Engineer and Project Manager and of the last NRC performance appraisal of my work.

One of the specific duties I performed as a Reactor Engineer for the AEC was to participate as the technical representative of the Directorate of Licensing on technical committees of the Institute of Electrical and

, Electronics Engineers (IEEE). I worked for a period of two to three years on

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lan IEEE committee developing standards to establish the minimum functional and design requirements for safety systems for nuclear power generating stations.

These requirements included thosa pertaining to the single failure criterion, environmental and seismic qualification of safety-related equipment, and the l independence.of redundant safety systems.

As part of my duties with the AEC and NRC, I performed technical reviews, analyses and evaluations of designs of systems and components necessary to the safe operation of reactor facilites under normal, abnormal and emergency 4

i conditions for the purpose of determining whether such systems complied with

'. NRC rules and provided an acceptable level of safety. Since coming to UCS, my job has required me to follow developments in the nuclear safety field. I testifed as an expert witness in the TMI-1 restart proceeding.

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Based upon my knowledge of NRC rules, engineering practice and nuclear plant design, I have reviewed the Three Mile Island Unit 1 emergency feedwater system. I have concluded that its design does not comply with NRC rules and that operation of TMI-1 would pose undue to risk to the health and safety of the public.

I drafted or supervised the drafting of all technical sections of the

" Union of Concerned Scientists' Petition for Show Cause Concerning TMI-1 Emergency Feedwater System," dated January 20, 1984. I have read the final version of that Petition. The facts contained therein are true and accurate to the best of my knowledge and belief, as are the technical opinions.

By d&P Robert D. Pollard Nuclear Safety Engineer Union of Concerned Scientists I hereby affirm that the foregoing is true and correct to the best of my knowledge and belief.

Robert D. Pollard Sworn and subscrit,ed before me this 2/Nday of January,1984, at Washington, D.C.

hM N Notary Public, 4 . O.

My commission expires /hM .?/j /f8 l

giacerical, inscrumentac ton ano Lnnt rol Sys tems Branch

. . . - , Dirretorate of Licensing FLTCTIONAL ST.\TF..MZNT: -

Servas as a highly qualific'd specialist in the field of reactor instrumentatic and control in performing technical revicus, analyses and evaluations of systc

( and component designs necessary to the safe operation under normal, cbnor:al

{ and emergency conditions of power, testing, production, and rascarch reactors, including DOD and AEC-owned reactors as well as licensed and authorir.ed facild ties.

RICULAR DUTIES: .

Participates as a senior member of the Directorate of Licensing, Electrical, Instru=entation and Control Systems Branch, whose function is primarily one af performing technical reviews, analyses, and evaluations of desigan of cys-tems and components necessary to the safe operation of reactor facilitics under nor mal, abnormal, and emergency conditions for the purpose of (a) determining the adequacy of the bases for such designs, (b) of determinin;; the adequacy of sbch designs to caet these bases and to withstand the lini:s o;~

environ = ental effects without loss of mini =um required functional capabilitics (c) of deter =ining the acceptability of procedures for fabrication, inspection testing, and post-licensing surveillance of such designs, and (d) of developin guidelina proceduras, ma~thods and models for the syste=atic evaluation of such designs by the Division. -

Reviews Safety Analysis Reports a.s to the adequacy of the presented data

pertaining to instrumentation, controls, and electric power and to the sound-

. ness of conclusions made on the basis of the presented infer:ation and prepare reports of such reviews.

Develops standard procedures, methods, and models for evaluations to determine

, whether or not the design of reactor protection syste=s, controls for engineer, safety features, safety aspects of regulating syste=s, and emergency power sys-reps is created in an acceptable manner.

Evaluates industry and AIC-sponsored research and development programs directes towards establishment of additional basic information on recctor instrumenta-tion and control, and to the use of such information for safety evaluation pur-poses, and correlates and interprets the results of such programs for the gene:

use of the regulatory staff.

Preparcs technical studies and reports bearing on' unique and unusual developne in the field of reactor plant instrucentation, control and electric power for ,

presentation of the ' Advisory Committec on Reactor Safeguards.

Recoa ends, through the Branch Chief, safety research progra=s to be sponsored by the AEC.

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Directorate of Licensing Pa e 2 Confers periodically wich technical representatives of industrial organizationa and other AEC divisions to discuss muclear safety proble=s involving arcas of concern related to reactor plant instrumentation, control and electrical power.

Participates, from time to time as technical representativa of the Directorate of Licensing on various AEC committcas, subcommittees, panels and task forca assignments as well as technical and professional society co :ittees such as the American National Standards'Instituta, tha A=arican Nuclear Society, the Institute of Electrical and Electronics Enginears, and othera.

EASIC SKILLS:

Ceneral knowledge of the principle =, theories, and practices in the ficid of nuclear engineering with specific knowledge of reactor plant instru=catation, control, and electric pouar systans is required. Competency must be suf fici-eat to independently analyze and evaluate reactor concepts and features pro-posed by organizations ppacializing in the nuclear field, particularly with respect to the reactor protection systems, instrumentation and control for engineered safety features, reactor regulating systems, reactor plant dynamics, and clectric power systems.

The basic skill require =ents are considerably in excess of those secured thrcosh fwscal educacion at university level (B.S. degrec) and are co= parable to those achieved from graduata leval training or from specialized experience

. in instrumentation and control in spplications to reactor technology.

Knowledge of licensed and authorized as well as DOD and AEC-owned reactor installations and operations is required.

CONTACTS:

Contacts top technical and supervisory personnel of the kEC,, other Covernment agencias, AEC contractors, industrial organizations, research institucions, universities, and professional societics to discuss ccchnical =atters relating to reactor plant instruecatation, control and electrical power syste=s .

RESPONSIBILITY FOR DECISIONS:

Supervision Received:

Chief, Electrical, Instru=catation and Control Systems Branch. Supervision is general on technical matters with full authority to act in ma tters within the fracawork of the broad functional assignment.

The Adainistrative guides are Division and overall AEC policy and precedcac.

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' Electrical, Instrumancation and Control Systems Branch Directorate of LicensinS Page 3 Independent Action: ,

Responsible for making reco:cand'acions for action to be taken by the Chief of the Electrical, Instrumentation and Control Systets 3 ranch, Develops standard procedures, =ethods, and codels for those sspects of safety evaluations involving physio-chemical considerations.

S*JPERVISION :

None

.  !?O.u!NC CONDITIONS: .

Normal offica conditions while at official station. E4 posure to mild radia-J.on from reactors m y be encountered occasionally during field trips.

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Nor=al effort involved.in any administra'oiva position. Increased physical effort cay be required while on field trips.

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Project 1:anso,cr, GS-14 Directorate of Licensi,ng FU.':CTIO.'!AL STATE!'.EhT s

Experienced in the engineering and physics aspects of nuclear retccors, the incu bent plans and coordinates the technical reviews, analyses, and evaluations of applications for licenses and authorizations f or the construction and operation of reactors and the reviews of certain aspects.of their design and operation.

REGULAR DUTIES . ,

. Plans and coordinates the pre-review of applications to determice if they are sufficiently complete to accept as an application.

Plans and, coordinates the review of Safety Analysis Reports as to the adequacy of the teghaical and engineering design data and information containad therein, the soundness of the basis for the conclusions of

" the proposed designs and operating procedures. Coordinates the pec-pacation of the safety evaluation in conjunction with such revicus.

Serves as project manager for group evaluation of pouer reacter license appitcants for which he has been assigned respcasibility, f

C:nfert with tc *.r. leal ..r e . 6.t tl... v' v. 3.i.1.. 1v..> e-vyv>;ug aus reactors to idantity or resolve general questions of doubt concerning design and operating characteristics which have a bearing on safety.

Coordinates the preparation of safety evaluation reports relating to license applications for power reactor plants, as well as etlit:ry and AEC reactor plants for presentation to the Advisory Cc =ittee on Reactor Safeguards. Attends such = eatings and subcc nittee ceecings as a representative of the Directorate of Licensing's evaluation staff.

Y.ay participate at public hearings on reactor licensing proceedin;s to assist other AEC representatives or testify as an AEC staf f witness

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to present technical testimony.

Serves as a ce:Ser of reactor inspection teams as aay be neccssary to discharge reactor safety evaluatica and judgment.

Plans and coordinates the review or nuclear safety aspects of proposals to build any AEC-owned reactors cpempt from licensing.

Assists in the prepration of technical specificaticas ice operating reactors; reviews operating experience reports during initial phases of operation; and evaluates requests for license amendments and technical specfication changes during initial phases of operation,

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utili:ing the e>partise of persons outside of his immediate division where necessary.

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B ASIC . SKILL

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Knowledge of the principles, theories and practices in the field of '

nuclear reactor technology with specific knculedge of reactor and nuclear engineering. Competence =us: be sufficient to adequately evaluata various proposed reactor concepts and modifications primarily as related to reactor construction and operation, e Knowledge of operations at AEC-owned reactor installations.

Experience in the field of reactor core design and operation to

,supplemen,c basic eqgineering training.

Basic skill requirements are in excess of those secured through fdtmal education at the university level CB.S. Degree) and are comparable to

,, those obtained frem graduate level trcining or specialized experience in reactor technology and related subjects. -

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CONTACTS Contacts are with top technical perso=nel in AZC, AEC contractorc, industry, and other, government agencies to discuss technical matters relating to the hacards inherent te design, operation, and site

~ location of proposed new reactors or significant modification of existing reactors.

RIS?ONSI3ILITY FOR DECISIONS .

Supervision Received Assigned Branch Chief, Directorate of Licensing.

Supervision is general on technical =atters, but specific on policy and operating procedures.

Administrative guides are AEC Manual, Co= mission Rules and Regulations.

and ,'.EC policy. Operational guides are in the for= of memoranda, uritten guides, precedent, and verbal directives. Incuchent contributes to the development of original standards, guides, and codes in his field of endeavor.

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Incu:::hent is. responsible for preparation of and adherence to review schedules and for caking recoc=acdations on conventional cagineering matters for action to be taken by tba Branch Chief in regard to the

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acceptability of the hazards involved in specific reactors.

Incuchenh's judgemmet, in many. cases, is subject to only a general review.-

SUPERTISION ~. . . . .

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• PERFORMANCE APPHAISAL AND RIIORD Or I::TERVIEU FOR NON-SUPERVISORY PROFESSIO::AL TECllNICAL E!!PLOYEE -

PROFILC NAME: Robert D. Pollard CRADE/ STEP: 14/2 POSITION: . ProjectManager/

/ TIM'E IN GRADE: 19 months W f9 D. f. assa/d b s

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APPRAISE.4 h DATP.: llo //--/4-/3 TIME Ii; STEP: 7 months

, l'EVIEWER & DATE: . D. 4 ung g //->J-h 1(p"DeYp//..=., -- TIME IN PREVIOllS (;P/J)C: 12 mo.

PREVIOUS APPRAISER & DATE: D. B. Vassallo AEC/fGC SERVICC (YEARS): 6-1/.

11/11/74 -

PROFESS 100:AL D:Pi:I:f r :t:E (Y:.AUS) llau IM C SUPERVISED BY APPRAISER: 13 months DATE OF BIRTH: 2/13/40 EDUCATION (DECREE 6 YEAR):

. B.S. (Elec. Eng.) 1969 4

DISCUSSION TOPICS BACKCROUND & EXPERIENCE SUMM\RY - Bob received a B.S. in Electrical Engineering from Syracuse University in 1969. Af ter joining the AEC in 1969, he studied electrical and nuclear engiacering at the Graduate School of.the University of New Mexico (1970-1971) in conjunction with the AEC Intern Program.

Bob' served-for six years with the U. S. Navy as an electronic technician.

He served as an instructor, reactor operator, and was in charge of the reactor control division aboard a nuclear-powered submarine.

After joining the AEC in July 1969, Bob participated primarily in technical revi n groups in the review of instrumentation, control, and electrical systems of nuclear power plants. For a brief period, he was a member of the Standards group'and participated in developing standards and safety guides. He also served as a member of IEEE Committees.

Bob' transferred s to RL as a project manager in September 1974.

KN0HLEDGE OF JOB - Although Bob has excellent expertise in the instrumentation, control,.and electrical systems of nuclear power plants, he has also developed very good overall knowledge of nuclear power plant design. Since transferring to RL, he has shown the capability to rapidly expand his knowledge and under-standing of the diverse technical review areas with which a project manager must be familiar. Although he may require a little more exposure in certain review areas (e.g., auxiliary systems and site related matters), Bob is 9

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on questionable technical matters and to pursue resolution of those in ,

controversy.

)! In a very short time, Bob has developed an excellent understanding of the technical, management, and administrative aspects of project management. d.

He manages to keep himself informed of current developments in technical, policy, legal, and general licensing matters. .

> MANAGEMENT CAPA3ILITY - Because.of his. pas.t experience in TR, Bob had a f good understanding of the LPN's role. He has made a very rapid transition y in assuming a project management philosophy. In the year that he has been ~

' in RL, he has demonstrated an excellent capability to manage radiolonical safety reviews. Bob is an exceptionally thorough project manager who ,

performs his tasks Oith a very critical view and in a very organi.ed manner.

He is very knowledgcable of, mnd quick to grasp and implement athe i n i s t r'a t iv e ,

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i procedures. He is very effective in maintaining full cognizance of all aspects of his projects. lie works very ef fectively with TR, OELD. and ' ,

applicant representatives and gets along very well with the branch secretaries go.g '

t- 8 and licensing assistant.

Bob has shown excell'ent capability to effectively organize and manag'c '

several concurrent projects. His principal assignment has been the OL t review of the McGuire plant. However, he was also assigned as the LPM for the completion of the Co,manche Peak and Catawba CP reviews. The latter required a considerable amount of LPM interaction with OELD because of'the applicant's request for an exemption from meeting the ECCS criteria. Bob j.

showed great adeptness at understanding and handling the unique tec'hnical -

Icgal aspects for bringing the Catawba project to an end; i.e., issuance gg of a CP. Because of the recent loss of an LPM f rom LUR l-1, Bob wa:s -

also assigned the task of completing the OL review of Indian Point 3, another project with a long history of complexities. In handling all of these projects, Bob has shown a great deal of resourcefulness in r.ioving these projects forward concurrently without diminishing his ef forts in any one of them. l%

PROFESSIONALISM - Bob is an extremely conscientious and dependabic project t I

=anager. He conducts himself with a degree of maturity and professienalism well beyond his age. In his associations with applicant representatives, he is very fair, but firm, and can take a stronc stance when the occasion varrants it. Bob does extremely well at planning and scheduling his

. workload. He is consistently able to comple te assig: ments on scnedule without needing reminders.  ;

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. Bob does not require much supervision. On the contrary, he seems to have a unique instinct of knowing' the type of licensing action that a situation

• requires and then begins to take the appropriate action without waiting for direction from the branch chief. In this regard, Bob has an out-standing knowledge of the Regulations and wcrks very effectively with lawyers (e.g., has prepared some quite involved technical - legal documents "

in conjunction with the Catawba and Indian Point 3 projects). He is very persistent in trying to get stalled actions moving. Bob does an excellent job of keeping his branch chief apprised of major review matters.

JUDCMENT - Bob is a careful thinker and-uses good logic in making judgments.

He has a very good understanding of the licensing program and uses goed judgment consistent with regulatory objectives.

COM>fUNICATIONS s

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Oral - Bob hag very good oral communication skills. He speaks clearly, with thought, and is very easily understood. He handles meetings extremely well. When he was a member of TR, he had considerable experience and was very effective in presentations before the

. . ACRS and was also exposed to public hearings.

Written - Bob writes extremely well. The documents he prepares are concise

. and clear. As mentioned above, he has a decided instinct for knowing the type of action required and can translate this in writing without any apparent difficulty. His written work requires very little editing.

PERSONAL CHARACTERISTICS - Basically, Bob is a very serious minded but personable. employee. He does not make rash decisions, b'u t rather uses a more deliberative approach. Bob manages to maintain a rather even composure no matter how difficult a situation may get. ,

Bob is an extremely conscientious, responsible, and depen'dable employce.

Occasionally he appears t.o become somewhat perplexed to rationalizing the implementation of licensinC Policy. In my opinion, this is because Bob has an exceptional understanding of the Commission's rules and regulations and takes his role of regulator very seriously. However, this has not affected his performance as a project canager.

AREAS NEEDING INPROVEMENT - Since transferring from TR, Bob is becoming exposed to a number of review areas with which he did not previously have '

a great deal of familiarity. These are principally in the areas of site safety, effluent treatment, and some portions of auxiliary systems. He has made great strides in understanding what the major review objectives are for these areas. With the continued expos,ure he is now obtaining in managing his projects, I do not foresce any problem in Bob becoming completely conversant in all review subjects.

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1. PROMOTION POTENTIAL - Bob haq shown* cxcellent project manage acnt capabil.ity.

He is well organized, is able to keep his projects under control, and to ,

meet schedule milestones. On the basis of his previous experience in TR and with further experience in project management, Bob has an excellent potential for attaining higher icvels.

SU) DIARY - Although Bob has been in RL for about one year, he has demonstrated excellent skills in managing safety reviews without requiring a great deal of supervision. Through his versatility, he has performed extrencly well in handling diverse assignments _in a,, highly professional manner; e.g., ,,

taking on the management of complex cases such as Catawba ead Indian Point 3 in the final stages of licensing ef fort.

REVIEUER'S CO 0!E!!TS h%A i<<3k l75., ,$u...t.

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/,-/.i- 70 DIPLOYEE' S C0! DIE ITS Acknowledgement I have read the above performance appraisal.

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Date: _

Co=nents by Employee NO 9

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UNITED STATES OF AMERICA C0(.KE TE D NUCLEAR REGULATORY COMMISSION

'84 JAN 23 Pl2:53 CERTIFICATE OF SERVICE OFFICE OF StCnt At 00CKEfir4G & SERV!b I hereby certify that copies of " Union of Concerned ScientistNNition for Show Cause Concerning TMI-1 Emergency Feedwater Sy: tem," have been served on the following persons by deposit in the United States mail, first class postage prepaid, this 20th day of January 1984.

Nunzio Palladino, Chairman Docketing and Service Section U.S. Nuclear Regulatary Commission Office of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Herzel Plaine, Esq.

Washington, D.C. 20555 General Counsel U.S. Nuclear Regulatory Commission James Asselstine, Commissioner Washington, D.C.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Henry D. Hukill Director of TMI-1 Frederick Bernthal, Commissioner GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P. O. Box 480 Washington, D.C. 20555 Middletown, PA 17057 Thomas Roberts, Commissioner Thomas A. Baxter, Esq.

U.S. Nuclear Regulatory Commission Shaw, Pittman, Potts & Trowbridge Washington, D.C. 20555 1800 M Street, N.W.

Washington, D.C. 20036 v