ML20023C040

Affidavit of Js Marshall in Response to ASLB Inquiry Re Classification of Equipment for Application of 10CFR50,App B Requirements & Relationship of Board Notification 83-13 to HR Denton 811120 Memo on Classification

ML20023C040
Person / Time
Site:	Comanche Peak
Issue date:	05/05/1983
From:	John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20023C035	List: ML20023C034 ML20023C037 ML20023C039 ML20023C040 ML20023C041 ML20023C042 ML20023C043
References
NUDOCS 8305090517
Download: ML20023C040 (7)

Text

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

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TEXAS UTILITIES GENERATING ') Docket Nos. 50-445 and COMPANY, -

et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

AFFIDAVIT OF JOHN S. MARSHALL REGARDING CLASSIFICATION OF SAFETY EQUIPMENT FOR APPLICATION OF 10 C.F.R. PART 50, APPENDIX B REQUIREMENTS I, John S. Marshall, being first duly sworn, do. depose and state as follows: I am employed by Texas Utilities Services, Inc. as Nuclear Licensing Supervisor. In this position I am responsible for assuring evaluation and resolution of licensing matters for the Comanche Peak Steam Electric Station. As such, I am familia r with Applicants' classification of safety equipment for application of 10 C.F.R. Part 50, Appendix B requirements. A statement of my professional qualifications is attached hereto.

This affidavit provides information in response to the Board's inquiry regarding the classification of equipment at Comanche Peak for application of 10 C.F.R. Part 50, Appendix B requirements. In addition, this affidavit addresses the 8305090517 830535 PDR T

ADOCK 05000445 PDR

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relationship of Board Notification 83-13 and the November 20, 1981 memorandum from Harold D. Denton regarding standard definitions for commonly-used safety classification terms.

I. Board Notification 83-13, EG&G Draft Report In inquiring into the classification of equipment at Comanche Peak, the Board referenced Board Notification ("BN")

83-13, "EG&G Draft Report on Identification and Ranking of Nuclear Plant Structures, Systems, and Components, and the Graded Quality Assurance Guidelines" (February 17, 1983) as being related to this inquiry. 1 As Applicants and the NRC Staff have noted, that Report concerns a possible mehns for identification and ranking, in order of importance co safety, of nuclear plant structures, systems, and components as well as graded quality assurance guidelines. 2 In BN 83-13, the Staff notes that while the information presented in the EG&G Report may provide guidance l for future changes in regulatory-requirements, it was not j presented in a manner that would permit incorporation into applicable regulations, such as General Design Criterion 1 of 10 C.F.R. Part 50, Appendix A. For this reason, and because the l

1 April 7, 1983, Conference Call, Tr. 31.

2 See " Applicants' Assessment of Relevance and Significance of Board Notifications" (March 18, 1983) at 14; NRC Staff i

letter to the Board, dated March 18, 1983, regarding Board Notifications.

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O Commission has not adopted the recommendations in the Report, Applicants have not addressed the specific classification schemes in the Report. I note, however, that some of the concepts presented in the Report regarding the application of 10 C.F.R.

Part 50, Appendix B to systems, components and structures "important to safety" are already employed by the NRC Staff and

utilized by Applicants.

1 II. Denton Memorandum On November 20, 1981, Harold R. Denton,-the NRC Director of t

the Office of Nuclear Reactor Regulation, transmitted a memorandum to all personnel in that Office regarding the use of standard definitions for commonly-used safety classification i terms. The Board has referred to this memorandum as possibly being relevant to its inquiry regarding the application of 10 i

C.F.R. Part 50, Appendix B requirements to various classes of safety equipment. 3 The purpose of the Denton memorandum was to establish " standard" terms to be applied by the NRC Staff for the classification of equipment in nuclear power reactors for the application of quality assurance requirements to that equipment.

3 April 7, 1983, Conference Call, Tr. 31.

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The Applicants' classification of equipment at Comanche Peak was reviewed by the NRC Staff prior to the issuance of the Denton i

memorandum. 4 These classifications are consistent with the Denton memorandum, and are discussed below.

I j III. Applicants' Classification of Safety Systems The safety classification of structures, systems and components for Comanche Peak are set forth in FSAR $3.2 and 8.1.

i The application of the requirements of 10 C.F.R. Part 50, Appendix B to these classes of items described in FSAR $ 3.2 and

8.1 is set forth in FSAR $17A. A list is presented in FSAR $17A i

l of the safety-related items for Comanche Peak which fall within i the scope of the quality assurance program. These items include structures, systems, and components or portions thereof that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

The structures, systems and components, which are classified as Safety Class 1, 2 or 3, Class lE or Seismic Category I, encompass the " safety-related" items described.in the Denton memorandum. See FSAR $$3.2,.8.1 and 17A.2. In addition, the quality list includes other items in the plant not classified as 4 See " Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station," NUREG-0797 (1981) ("SER") Section 3.2; SER Supplement No. 1 (October

> 1981), Section 17.5.

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cafety-related but for vbich some degree of quality assurance was applied during design and construction. These items are those which augment the reliable performance of safety-related items or which reduce risk to the health and safety of the public but which are not classified as Saftty Class 1, 2 and 3, Seismic Category I or Class 1E. FSAA 517A.l.

In sum,10 C.F.R. Part 50, Appendix B requirements are ~

not imposed simply on the syste:ns or cc:nponents which are safety-related, but on other ite:ns in accordance with their ir.portance to safety, as conte = plated by the Denton memorandum.

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. Johns.Marsfil County of Dallas )

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State of Texas )

Subscribed and sworn to before me this 5th day of May, 19S3, -

.cd.o tfotary Public.

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This is a telecopy facsimile. The original will be transmitted under separate cover.

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1 JOHN S. MARSHALL STATEMENT OF EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS POSITION: Nuclear Licensing Supervisor

FORMAL EDUCATION

1964-1968, B.S. Naval Engineering, United States Naval Academy EXPERIENCE:

1980 - Present Texas Utilities Services Inc. as Nuclear Licensing Supervisor.

Responsible for the interpretation and application of NRC safety and licensing requirements, as well as resolution of all technical matters with the NRC Staff. Responsible for publishing and maintaining Final Safety Analysis Report for Comanche Peak Steam Electric Station.

1979 - 1980 Texas Utilities Services Inc. as a Nuclear Licensing Engineer.

Responsible for assuring the CPSES design met NRC licensing requirements and Safety Analysis Report comittments for emergency core cooling systems, Category I structures, radwaste systems, radiation monitoring systens and radiation shielding.

1974 - 1979 Bechtel Power Corporation. Design and licensing of balance of plant i systems for foreign and domestic nuclear power plants: Vogtle -

Westinghouse NSSS; Rancho Seco Unit 1 - Babcock & Wilcox NSSS; Palo

' Verde, Units 1, 2 and 3 - Combustion Engineering NSSS; San Onofre, Units 2 and 3 - Combustion Engineering NSSS; Kuosheng (Taiwan) - General Electric NSSS.

1964 - 1974 U.S. Navy Nuclear Submarine Service; Qualified Nuclear Engineer Officer; supervised operation of nuclear reactors while serving as Navigator and Operations Officer, USS John

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l Adams (SSBN-620); Engineering Division Officer, USS Grayling (SSN-646).

PROFESSIONAL SOCIETIES: American Nuclear Society - Member i

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