ML20023E235

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Response to 830419 Questions & Document Request Re Contentions III & IV
ML20023E235
Person / Time
Site: Clinton Constellation icon.png
Issue date: 05/23/1983
From: Patterson W
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: William P
ILLINOIS, STATE OF
References
ISSUANCES-OL, NUDOCS 8306150226
Download: ML20023E235 (22)


Text

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May 23, 1983 Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street, Suite 2315 Chicago, Illinois 60601 In the Matter of ILLIN0IS POWER COMPANY, et al.

(Clinton Power Station, Unit 1 Docket No. 50-461 OL

Dear Mr. Willman:

The NRC staff has prepared in the context of informal discovery the enclosed responses to the questions that accompanied your letter of April 19, 1983, concerning Contentions III and IV. Also enclosed are the documents that you requested in your letter.

Sincerely, William F. Patterson, Jr.

Counsel for NRC Staff

Enclosures:

As stated cc: w/ enclosures Reed Neuman, Esq.

Jean Foy Sheldon A. Zabel, Esq.

Distribution Patterson/ Goddard Lessy/Reis Murray/Christenbury Lieberman/0lmstead (PACW[

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o ENCLOSURE 1 RESPONSES TO INFORMATION REQUEST CONTENTION III The design and fabrication of the CPS Control Room layout and instrumentation have not been modified to meet current regulatory requirements in NUREG's-0660, 0694, and 0737.

Part (b)

The CPS lacks sufficient instrumentation for detecting inadequate core cooling in case of an abnormal occurrence.

Item 1 The NRC Staff did not provide any affidavits relevant to this contention.

Response to Item 1 The staff is presently reviewing the adequacy of instrumentation for detection of inadequate core cooling (ICC) as a generic concern relevant to all BWR's.

In response to staff concerns, the BWROG contracted a study to evaluate the adequacy of existing water level instrumentation as an indication of ICC and to evaluate the need for additional instrumentation for reliable indication of the approach and existence of ICC and recovery from that condition.

The BWROG submitted a report to the staff in August 1982 entitled,

" Review of BWR Reactor Water Level Measurement Systems", SLI-8211 dated July 1982, which includes the BWR0G's evaluation of existing water level instruments and recommendations for their improvement.

In December 1982 they also submitted a second report entitled, l

" Inadequate Core Cooling Detection in BWR's", SLI-8218 dated November 1982, which presents evaluation results of additional instrumentation as diverse indicators for ICC with recommendations regarding the need for such additional instrumentation (including in-core thermocouples) for BWR plant monitoring systems. The staff expects to complete its review of the BWROG reports in Fall 1983. The applicant will be

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required to submit a plant specific evaluation addressing the appli-cability of the BWROG findings (report SLI-8211 and SLI-8218) to l

Clinton for staff approval.

Part (d)

A Safety Parameter Display System should be, but is not, provided for in the main control room.

Item 1 Has the NRC staff adopted as staff policy the requirements in SECY-82-111 that are applicable to Safety Parameter Display Systems (SPDS)?

If so, (a)

Is Illinois Power required to comply with these requirements?

Explain the basis for your answer.

(b) Has Illinois Power complied with these requirements? Explain the basis for your answer.

Response to Item 1 SECY-82-111B was approved by the NRC in July 1982, and as a result, on December 17, 1982, the Commission issued Supplement No. 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter No. 82-33). Generic Letter 82-33 (attached) provides a distillation of the basic requirements for Safety Parameter Display Systems, Detailed Control Room Design Reviews, Regulatory Guide 1.97 (Revision 2) - Application to Emergency Response Facilities, Upgrade of Emergency Operating Procedures, Emergency Response Facilities, and Meteorological Data.

Per Generic Letter 82-33, these requirements are applicable to applicants for operating licenses.

In its letter to the NRC dated April 13, 1983, the Illinois Power Company (IPC) states that it has " developed an integrated implementation program that responds to the requirements of Generic Letter 82-33."

IPC committed to provide the implementation schedule in June 1983.

Item 2 If the answer to Question 1 is no, when will NRC establish SPDS requirements?

Response to Item 2

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Per the response to Item 1 above, the NRC established SPDS requirements in Supplement No. I to NUREG-0737 (Generic Letter 82-33).

Item 3 Is the Clinton SPDS capable of supplying data to the emergency opera-tions facility and the technical support center for use in post-accident decisions?

If not, why not?

Response to Item 3 This question will be addressed as part of-the NRC review of the Clinton SPDS.

Specific information regarding this question is not currently available.

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Item 4 Who supplied the Clinton SPDS?

Response to Item 4 See Response to Item 3.

Item 5 What are the display capabilities of the Clinton SPDS?

Response to Item 5 See Response to Item 3.

Item 6 What are the trending capabilities of the Clinton SPDS?

Response to Item 6 See Response to Item 3.

Item 7 Does Illinois Power plan to install a permanent (final) SPDS?

If so, when?

Response to Item 7 IPC has committed to install an SPDS as required by Supplement No.1 to NUREG-0737.

In June 1983, IPC will provide the date when the SPDS will be operable and when the operators will be trained in its use.

Part (e)

The CPS lacks adequate instrumentation for monitoring accident conditions.

Item 1 What instrumentation has Illinois Power committed to install, pursuant to Item II.F.1 of NUREG-0660?

Response to Item 1 The attached letter from J. D. Geier of IPC to J. R. Miller of NRC dated December 2,1981, describes the instrumentation Illinois Power has committed to install pursuant to Item II.F.1 of NUREG-0660.

Item 2 What instrumentation has Illinois Power committed to install, pursuant to Item II.F.2 of NUREG-0660?

Response to Item 2 A clarification of the requirements for detection of inadequate core cooling specified in Item II.F.2 of NUREG-0660 was provided in Section II.F.2 of NUREG-0737. Responding to the requirements in Section II.F.2 of NUREG-0737, Illinois Power Company has committed to work through the BWR Owners Group to address the staff concerns for detection of inadequate core cooling (see response to III.(b)).

Item 3 What instrumentation has Illinois Power committed to install, pur-suant to Item II.F.3 of NUREG-0660?

Response to Item 3 Section II.F.3, " Instruments for monitoring accident conditions",

of NUREG-0660 requires that a program to install or upgrade the appropriate accident monitoring instrumentation be developed and implemented. Guidance for this instrumentation (including variables to be monitored and applicable design and qualification criteria) is contained in Regulatory Guide 1.97, Revision 2, (R.G.1.97, Rev. 2),

" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident."

Generic Letter 82-33 dated December 17,1982 (Supplement No.1 to NUREG-0737, Reauirements for Emergency Response Capability) provided additional clarification for several of the TMI Action Plan items, including implementation of R.G.1.97, Rev. 2.

This letter, pursuant to 10 CFR 50.54(f), requested that operating reactor licensees and holders of construction permits submit proposed schedules for completing the requirements for these items by April 15, 1983. By letter dated April 13,1983 from D. P. Hall (IPC) to A. Schwencer (NRC), Illinois Power submitted its plan for implementation of these items at Clinton i

and has committed to provide a detailed implementation schedule in June 1983. This is acceptable to the staff.

Illinois Power has stated in the April 13, 1983 letter that some additional instruments and/or upgrading of existing instruments will be required for Clinton. Procurement of these instruments is currently I

underway.

Illinois Power has also stated that the instruments used for accident monitoring to meet the provisions of R.G.1.97, Rev. 2 shall have the proper sensitivity, range, transient response, and accuracy to ensure that the plant can be brought to and maintained in a safe shutdown condition. This instrumentation will be qualified l

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to the appropriate levels and will comply with applicable quality assurance requirements.

Illinois Power has committed to submit de-

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tailed information describing how the instrumentation installed at Clinton will meet the provisions of R.G.1.97, Rev. 2 and to justify any deviations from the guidance in this R.G.

The staff will perform an audit review of this instrumentation in accordance with the implementation schedule to be provided by Illinois Power (assuming that this schedule is acceptable) to assure that adequate accident monitoring instrumentation is installed at Clinton.

Item 4 What instrumentation has Illinois Power committed to install, pursuant to Reg. Guide 1.97, Rev. 2?

Response to Item 4 The answer to this question is provided in the response to Item 3 above.

Item 5 What schedule has the NRC staff set for Illinois Power to implement the Reg. Guide 1.97, Rev. 2 requirements at Clinton?

Response to Item 5 The staff has not set forth a specific schedule for Clinton. The staff has requested that Illinois Power propose a schedule for imple-menting the provisions of R.G.1.97, Rev. 2 as indicated in the response to Item 3 above. _The staff will work with Illinois Power to develop an approved schedule for implementation and staff review of the accident monitoring instrumentation at Clinton once this information is received. The staff philosophy with respect to implementing the requirements of Generic Letter 82-33 is to allow the utilities to establish the schedules since an integrated approach to completing these items is required (i.e., the R.G.1.97, Rev. 2 instrumentation, safety parameter display instrumentation, emergency support facility l

modifications, control room design review, etc. are all interrelated activities for which completion dates can best be determined on a plant specific basis).

Item 6 Has Illinois Power committed to install in-core thermocouples, as specified in Regulatory Guide 1.97, Revision 27

Response to Item 6 Illinois Power Company has not committed to install in-core thermo-couples, but is working through the BWR Owners Group to address the staff concerns for inadequate core cooling (ICC) detection (also see response to III.(b)). The current version of Revision 3 of Regulatory Guide 1.97, which has not been published, indicates that the require-ment for BWR in-core thermocouples is still under review. The staff expects that the review results may eliminate the requirement of in-core thermocouples for detection of ICC.

Item 7 What position does the NRC staff take with respect to the use of in-core thermocouples?

Response to Item 7 The staff does not presently require installation of in-core thermo-couples in BWR's because in-core thermocouples alone are not well-responding, unambiguous indicators of inadequate core cooling ander some conditions.

Instead of requiring installation of in-core thermo-couples, the staff is providing BWR Owners an opportunity to demonstrate the adequacy of existing water level instrumentation for detection of inadequate core cooling (ICC) and to evaluate the feasibility and need for additional instrumentation for detection of ICC.

The applicant is a member of the BWR Owners Group (BWROG) which has responded to staff cencerns on this issue (also see response to III.(b)).

Results of the staff review of BWROG submittals, including conclusions regarding the need for in-core thermocouples, will be applied to Clinton.

Item 8 Has the NRC staff required Illinois Power to use an unambiguous indication'of the onset of inadequate core cooling?

Response to Item 8 Yes.

A clarification of requirements for inadequate core cooling instrumentation was provided in Section II.F.2 of NUREG-0737, "Clari-fication to TMI Action Plan Requirements."

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CONTENTION IV The CPS Emergency Core Cooling System (ECCS) has not been demonstrated to meet the requirements of 10 CFR Part 50.46 and 10 CFR Part 50, Appendix A.

Part (a)

In noncompliance with 10 CFR Part 50.46, the core spray distribution of CPS's ECCS is of unproven operating capability.

Item 1 Has the NRC staff, or any consultant to the NRC, evaluated recent Japanese tests on the core spray distribution for BWR's?

If so, describe the conclusions of that evaluation.

Response to Item 1 Yes. The staff evaluated the Japanese tests in conjunction with other core spray test data and results of analyses performed for BWR/1 and BWR/3 through BWR/6 reactors. As described in the attached reference *, we conclude that the core spray distribution is not a safety concern for BWR/1, BWR/3, BWR/4, BWR/5 and BWR/6 reactors (Clinton is a BWR/6 reactor).

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  • Memorandum from R. J. Mattson (NRC) to T. Speis (NRC), "Close-out of Tap-A-16, Steam Effects on BWR Core Spray Distribution", March 29, 1983.

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/LLINO/S POWER 00MPANY 500 SOUTH 27TH STREET, DECATUR. ILLINOls 62525 N, g%-

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'..U Mr. James R. Miller, Chief Standardization & Special Projects Brar gh DEC1 1981 11 4 Division of Licensing Office of Nuclear Reactor Regulation k..**c-Ji#$ ".

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Dear Mr. Miller:

Clinton Power Station Unit 1 Docket No.

50-461 The attached material represents responses which were discussed with Messrs Larry Ruth, Richard Bangart and Michael LaMastra on December 1, and 2,1981.

These responses were found to be acceptable as stated and resolve the issues. The following items addressed in TMI Action Plan Item II.F.1 are classified as confirmatory:

Noble Gas Effluent Radiological Monitor Provisions for Continuous Sampling of Effluent Containment High-Range Radiation Monitor Containment Pressure Monitor Containment Water Level Monitor Containment Hydrogen Concentration Monitor Sincerely,

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Geier Manager, Nuclear Station Engineering k

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J.H. Williams, NRC Clinton Project Manager L

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H.H. Livermore, NRC Resident Inspector L. Ruth, NRC CSB 9Qg{ /.ast 4.

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R. Bangart, NRC ETSB M. LaMastra, NRC Radiological Assessmen.t Branch W "M 811202

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Issue:

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TMI Action Plan Item II.F.1 Additional Accident Monitoring Instrumentation NUREG-0737 Item II.F.1 requires that the following additional accident monitoring instrumentation be provided:

a.

Noble gas effluent radiological monitors; b.

Provisions for continuous sampling of plant effluents for postaccident releases of radioactive iodines and particulates, and onsite laboratory facilities; c.

Containment high-range radiation monitor; d.

Containment pressure monitor; e.

Contaimnent water level monitor; and f.

Containment hydrogen concentration monitor.

Response

a.

Noble Gas Effluent Radiological Monitor Illinois Power Company commits to installing Noble Gas Effluent Radiological Monitors as specified by Table II.F.1-1 of NUREG-0737. The design details of this monitoring system will be provided no later than four months prior to the issuance of an operating license.

b.

Sampling and Analysis of Plant Effluents Illinois Power Company commits to provide for continuous sampling of plant gaseous effluent for post accident releases of radioactive iodines and particulates as specified ~ hy Table II.F.1-2 of NUREG-0737. The design details of this sampling system will be provided no later than four months prior to issuance of an operating license.

c.

Containment.High-Range Radiation Monitor Illinois Power Company co mits to installing Containment High-Range Radiation Monitors as specified hy Table II.F.1-3 of NUREG-0737. A plant drawing indicating the location of the monitors and the design details of this monitoring system I

will be provided no later than four months prior to the issuance of an operating license.

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Containment Pressure Monitor D

Illinois Power Company will provide for continuous measurement and indication of containment pressure over the range from -5 psig to three times the concrete containment design pressure. -Containment pressure will be displayed and recorded in the main control room.

The design details of this monitoring system will be provided no later than four months prior to the issuance of an operating license.

e.

Containment Water Level Monitor Illinois Power Company will provide for continuous indication of suppression pool level over the range from the ECCS suction line inlets to five feet above the normal water level. The pool level indication will be providad in the main control room. The design details of this monitoring system will be provided no later than four months prior to the issuance of an operating license.

f.

Containmcnt Hydrogen Monitor Illinois Power Company will install a continuous hydrogen indication in the control room. The capability covers the range of 0 percent to 10 percent hydrogen concentration by volume over a pressure range of negative 0.5 pounds per square inch gauge to 30 pounds per square inch gauge.

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These monitoring units have an accuracy of + 10 percent of span which is judged to be acceptable. The design details of this monitoring system will be provided no later than four months prior to the issuance of an operating license.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION m

BEFORE THE ATOMIC SAFETY AND LICENSING BOAR a

In the Matter of Docket No. 50-461 OL

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ILLIN0IS POWER COMPANY, _et _al. )

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(Clinton Power Station, Unit 1)

AFFIDAVIT OF HARVEY ABELSOff I, Harvey Abelson, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a Licensing, Office 1.

Licensing Pro,iect Manager, Licensing Branch 2, Division of A copy of my professional qualifications of Nuclear Reactor Regulation.

III(e),

is attached.I have provided the response to Item 1, relating to Contenti 2.

R. Goddard, set forth in an enclosure to a letter from P. Willman to 19, 1983.

to dated April I hereby certify that the above statements are true and correc the best of my knowledge and belief.

Y' fdd HarveyjAbelson Subscribed and sworn to before me 1983 this 904 day of W 64

. #&d4 Notary Public 7///k My comission expires:- ~/ /

PROFESSIONAL QUALIFICATIONS OF p'

HARVEY I. ABELSON, P.E.

EDUCATION B.M.E. Cooper Union 1963 M.S. (Applied Mechanics) Stevens Institute of Technology 1965 Ph.D (M.E.) University of Maryland 1969 EMPLOYMENT HISTORY U. S. Nuclear Regulatory Commission (Bethesda, MD) 1981 - Present Argonne National Laboratory (Argonne, ILL) 1979 - 1981 MITRE Corporation (McLean, VA) 1975 - 1979 Bechtel Power Corporation (Gaithersburg, MD) 1974 - 1975 Manhattan College (Bronx, NY) 1970 - 1974 U. S. Naval Ordnance Laboratory (White Oak, MD) 1964 - 1970 PROFESSIONAL / BUSINESS ACTIVITIES Director / Proprietor - Engineering Review Programs of Greater Washington Examination Consultant - National Council of Engineering Examiners Adjunct Engineering Faculty - George Washington Uniyersity (1980 - Present)

Board of Directors, ASME Washington, DC Chapter (1980 - Present)

EXPERIENCE-U. S. Nuclear Regulatory Commission Project Manager - Division of Licensing, Office of Nuclear Reactor Regulation Management of radiological safety and environmental reviews of Operating License applications for Limerick Generating (Station (Philadelphia Electric Company) and Clinton Power Station Illinois Power Company)

Principal NRC liaison with the utilities and the public regarding all matters related to licensing Responsibility for coordination of review efforts of 30 technical review branches, publication of key staff review documents and coordination of licensing hearing activities Coordination of Probabilistic Risk Assessment review activities for Limerick 4

2-Harvey I. Abelson, P.E.

6 Argonne National Laboratory Mechanical Engineer and Washington representative for Energy and Environmental Systems Division Project manager for Ocean Thermal Energy Conversion (OTEC) power system performance and cost modeling; design a t

and-tube and compact heat exchangersDOE Technical Advisory Pa tions, development of evaluation criteria, and contractor technical Principal investigator on metal hydride heat pump development project; reviews system thermodynamic analysis, sensitivity ana of heat transfer coefficients and thermal gradients Planning for second deployment of OTEC-1 test ship; hardware selectio layout, test plans, performance evaluations of proposed system config Technical liaison activities in Washington on OTEC program and other rations division programs MITRE Corporation _

Technical Staff - Energy and Environment DivisionTherma (OTEC) power systems, coal and wood combustion systems, and solar-Member of DOE OTEC Power Systems Technical Advisory Panel; technic thermal power systems evaluations of contractor outputs; capital cost analysis of proposed Project manager of EPA contract involving environ power systems and analysis of stack gases and solid residues Bechtel Power Corocration_

development of in-house Technical training coordinator for engineering:

training programs and graduate programs with local universities analysis of SNUPPS nuclear' power plant project Balance-of-Plant Group:

Ultimate Heat Sink cooling towers and cooling ponds; analysis of heat loads on Essential Service Water System during AEC Regulatory Guide 1.27 seismic, thermal, and dynamic analysis of piping systems; computation of forces from valve blowdown; non-linear d SNUPPS Stress Group:

analysis of pipe whip using ANSYS code l

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Harvey I. Abelson, P.E. y Manhattan College l

Assistant Professor of Mechanical Engineering Taught Fluid Mechanics, Thermodynamics, Mechanics of Deformable Bodies, Computational Methods, Gas Dynamics, Advanced Fluid Dynamics, Advanced Engineering Mathematics, Dynamics, Machine Design, Mechanical Engineering i

Laboratory

  • -Curricula development and planning for design-oriented Master's Degree program i

Studies on modeling techniques for wind-driven, large-scale circulations l

in lakes Faculty advisor for AIAA student section U. S. Naval Ordnance Laboratory Research Mechanical Engineer - Hydroballistics and Mechanics Division Principal investigator on experimental and analytical study of the i

water-entry problem; Study addressed impact, cavity, trajectory, and stability aspects, with focus on cavity pressure and shape; Time history and spatial variation of pressure in the water-entry cavity and surrounding flow field were measured and' correlated with high-speed underwater photography of events; Analytical models to predict transient cavity shapes.and pressures ~ were developed; Hydrodynamic i

theory, particularly the method of singularities, and one-dimensional i

unsteady gas dynamic theory were applied here; Additional studies addressed scaling laws, gas bubble dynamics, and splash behavior Studies of stress-wave propagation in materials with applications to i

shock mitigation using Hopkinson bar apparatus and method of charac-L teristics; missile penetration studies l

Development of air-to-surface and air-to-water weapon systems Part-Time Teaching George Washington University: Analytical Mechanics, Thermodynamics Catholic-University (Continuing Education):

Principles of Engineering for Professional License Preparation and General Review; Review of Thermal Sciences for Energy System Analysis PE/EIT courses taught for:

IEEE-ASME N.Y.C. Metropolitan Section, -

NYSSPE Westchester Section, Consolidated Edison, Burns & Roe, Bechtel, Catholic University, Engineering Review Programs of Greater Washington l

MAJOR PUBLICATIONS Energy, July 1981 (ysis of a Metal Hydride Heat Pump", AIAA Journal of

" Thermodynamic Anal i

principal author); Also presented at 15th Intersociety i

Energy Conversion Engineering Conference, Seattle, August 1980 Analytical Methods for Coal and Coal Products (2 Volumes), Academic Press, 1

Inc., January 1979; Principal author of two chapters on " Sampling and Analysis of Emissions from Fluidized-Bed Combustion Processes" l

Harvey I. Abel son, P.E. i "0TEC Power System Performance Model", MITRE Report MR-7924, August 1978

" Pressure Measurements in the Water-Entry Cavity", Journal of Fluid Mechanics, Volume 44, Part 1,1970 "A Prediction of Water-Entry Cavity Shape", Trans. of ASME Journal of Basic Engineerino, Volume 93, No. 4,1971 (Presented at ASME Winter Annual Meeting, 1970)

PROFESSIONAL AFFILIATIONS Member - American Society of Mechanical Engineers Member - American Society for Engineering Education Member - Society of Sigma Xi Registered Professional Engineer - New York State f

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

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)

ILLIN0IS POWER COMPANY, et _al.

)

Docket No. 50-461 OL

)

(Clinton Power Station, Unit 1)

)

AFFIDAVIT OF RICHARD A. KENDALL I, Richard A. Kendall, being duly sworn, state as follows:

1.

I am employed by the ll.S. Nuclear Regulatory Commission as a Reactor Engineer (Instrumentation) in the Instrumentation and Control Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached.

2.

I have provided responses to Items 3 through 5, relating to Contention III(e), set forth ia an enclosure to a letter from P. Willman to R. Goddard, dated April 19, 1983.

I hereby certify that the above statements are true and correct to the best of my knowledge and belief.

x2 D Richard' A. KEnda' i

Subscribed and sworn to before me thisJo* day of 1983 afk:Ad#'M Notary Public My commission expires:

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RICK KEliDALL DIVISION OF SYSTEMS INTEGRATION U. S. NUCLEAR' REGULATORY COMMISSION PROFESSIONAL QUALIFICATIONS I have been with the U. S. Nuclear Regulatory Commission since June 1979.

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l am a Reactor Engineer (Instrumentation) in the Instrumentation and Control Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

I serve as a reviewer in the area of nuclear power plant instrumentation and control systems in perfonning and coordinating. reviews and evaluations of those portions of the applications for Construction Pennits and Operating Licenses and submittals regarding proposed modifications in licensed nuclear power plants for which the branch has responsibilit to assure public health and safety and pro-tection'of the environment.

I serve as project leader and coordinator of other reviewers for the resolution of technical issues and licensing problems and provide technical assistance and advice in the areas relating to the safety aspects of reactor plant instrumentation and control systems and components.

I received a Bachelo.r of Science degree in Electrical Engineering from the University of Maryland (College Park) in 1979.

Previously I had received an Associate of Arts degree in Electrodic Technology from Montgomery College?

(Rockville,Md.).

Other educational background includes the following courses:

System Reliability Engineering and Risk Assessment - JBF Associates, Inc.;.

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. i fundamentals of System Grounding Protection - IEEE; Boiling Water Reactor Simulator School - flRC; Pressurized Water Reactor Simulator School - flRC; Pressurized Water-i Reactor Technology (2 courses) - NRC; Boiling Water Reactor Technology - NRC.

In 1978 and 1979 I was employed by the University of Maryland Astronomy Department I

as an electronic technician with such duties as designing, constructing, and re-pairing digital systems (and supporting systems).to display and record data received from telescope photomultiplier tubes at the university observatory. I am currently a member of the Institute of Electrical and Electronics Engineers (IEEE).

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

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)

ILLIN0IS POWER COMPANY, et _al.

)

Docket No. 50-461 OL

)

(Clinton Power Station, Unit 1)

)

AFFIDAVIT OF SUMMER SUN I, Summer Sun, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer in the Core Performance Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. A copy of my profess.ional qualifications is attached.

2.

I have provided responses to Item 1, relating to Contention III(b),

Items 2, 6, 7 and 8, relating to Contention III(e), and Item 1, relating to Contention IV(a), set forth in an enclosure to a letter from P. Willman to R. Goddard, dated April 19, 1983.

I hereby certify that the above statements are true and correct to the best of my knowledge and belief.

M.

3ummer Sun Subscribed and sworn to before me this AWL day of W7 1983 47fd~Au df/- M Notary Public

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My comission expires: 7///R

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e Summer B. Sun Core Performance Branch Division of Systems Integration U. S. Nuclear Regulatory Commission PROFESSIONAL QUALIFICATIONS I am employed as a nuclear engineer of the Thermal-ilydraulics Section in the Core Performance Branch of the Division of Systems Integration.

I received a Ph.D degree with Chemical Engineering Major from University of Missouri of Columbia, Missouri, in 1974.

I am a registered Professional Engineer, Certificate Number 11309, in the state of Connecticut.

In my present work assignment at the NRC, I have technical responsibility I

for the4 review of the reactor core thermal-hydraulics design submitted in BWR reactor construction pennit and operating license applications.

In addition, I participate in the review of analytical models used in licensing evaluation of the core thermal-hydraulic behavior under various operating and postulated accident and transient conditions.

The latter responsibility includes technical review of the instrumentation for monitoring inadequate core cooling to comply with the Commission requirements.

Prior'to joining the NRC staff in August'1980, I was snployed by Combustion Engineering Company, as a consulting engineer.

I was responsible for the development and application of computer codes for the analysis of transients for PWRs.

I acted as a consultant to the Safety Analysis Section of Combustion Engineering Company (CE) in the use of these codes for analysis of CE plants in the area of safety and perfonnance analyses.

My tenure at CE was from 1974 through 1980.

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

)

ILLIN0IS POWER COMPANY, el a_1,.

Docket No. 50-461 OL (Clinton Power Station, Unit 1)

)

AFFIDAVIT OF ANN M. RAMEY-SMITH I, Ann M. Ramey-Smith, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as an i

Engineering Psychologist in the Human Factors Engineering Branch, Division of Human Factors Safety, Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached.

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2.

I have provided responses to Items 1 through 7, relating to Contention III(d), set forth in an enclosure to a letter from P. Willman l

to R. Goddard, dated April 19, 1983.

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I hereby certify that the above statements are true and correct to the best of my knowledge and belief.

Ann M. Ramey-Smith /

l Subscribed and sworn to before me thisA3J day of iMPf 1983 42 h

l Notary Publir My connission expires: ~)///74 l

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ATTACHMENT 3*

ANN M. RAMEY-StilTH PROFESSIONAL QUALIFICATIONS HUMAN FACTORS ENGINEERING BRANCH DIVISION OF HUMAN FACTORS SAFETY Since March 1981 when I was hired by the USNRC I have been assigned to the Human Factors Engineering Branch, Division of Human factors Safety, Office of Nuclear Reactor Regulation.

My initial responsibilities included:

(1) partici-pation in the development of NUREG-0700, " Guidelines for Control Room Design Reviews", and (2) participation in the onsite control room design reviews required for operating licenses.

Subsequently, I have participated in four control room design reviews, three of which I directed.

.I have been active in the application of human factors psychology since 1974.

I hold a bachelor of science degree and a masters of arts degree in Psychology from Towson State University.

I have completed four NRC-sponsored courses entitled Nuclear Reactor Concepts, Radiation Safety Training Program, Pressurized ' Water Reactohs Technology Course, and Boiling Water Reactors Technology Course.

I am a member of the Human Factors Society.

~

From 1974 until joining the USNRC in 1981, I was employed as a Research Psychologist at the National Bureau of Standards. The National Bureau of Standards (NBS) is a Federal research and development agency and is part of the U. S. Department of Comerce. At NBS I worked in the Technical Analysis Division and then in the Center for Consumer Science Technology in planning, directing, and implementing research in the psychological and human factors aspects of man / machine interactions across a broad range of applications.

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ENCLOSURE 2 DOCUMENTS REQUESTED Items 1, 2 and 3 1.

All documents related to the NRC Human Factors Engineering Branch audit of the CPS control room.

2.

All documents related to the audit by Illinois Power or its consultant of the CPS control room.

3.

All documents related to Illinois Power's response to the NRC staff's control room audit.

Response to Items 1, 2 and 3 The following documents are enclosed in response to Items 1, 2 and 3:

Letter:

From G. E. Wuller (IPC) to J. R. Miller (NRC) dated October 5,1981 Letter: From G. E. Wuller (IPC) to J. R. Miller (NRC) dated November 17, 1981 Letter: From G. E. Wuller (IPC) to J. R. Miller (NRC) dated November 25, 1981 Memorandum: From J. J. Kramer (NRC) to R. L. Tedesco (NRC) dated December 4,1981 Memorandum: From V. A. Moore (NRC) to J. R. Miller (NRC) dated December 8,1981 Letter:

From G. E. Wuller (IPC) to J. R. Miller (NRC) dated January 13, 1982 Letter:

From T. F. Plunkett (IPC) to J. R. Miller (NRC) dated February 9,1982 Memorandum: From H. L. Thompson (NRC) to R. L. Tedesco (NRC) dated February 17, 1982 Letter:

From J. G. Cook (IPC) to A. Ramey-Smith (NRC) dated April 8,1982 Memorandum: From V. A. Moore (NRC) to J. R. Miller (NRC) dated May 6,1982 Memorandum:

From V. A. Moore (NRC) to J. R. Miller (NRC) dated July 9,1982 Letter:

From D. P. Hall (IPC) to A. Schwencer (NRC) dated April 13, 1983 NUREG-0660, Vol.1, May 1980 NUREG-0700, September 1981 NUREG-0737, November 1980 Supplement No.1 to NUREG-0737 (Generic Letter 82-33)

Item 4 All documents related to the NRC staff's response to the BWR Owners G in Reg. Guide 1.97, Rev. 2.

Response to Item 4_

The staff has not completed its review of the BWR Owners Group resp 8

This response dated April 6,1983, was submitted in accordance f construction Rev. 2 at this time.

with Generic Letter 82-33 which required that licensees and holders ol TMI permits submit proposed schedules for completing the requirements of sev The review of the BWR Owners Action Plan items including R.G.1.97, Rev. 2.

i Group submittal will be performed for NRC by EG&G as part of our t This submittal is currently under review by EG&G (this review has just recently been started) and is scheduled to be one of the first rev contract program.

h to be completed since a number of BWR applicant submittals have referenc Owners Group response to R.G. 1.97, Rev. 2.

We anticipate that our review of the Owners Group respon mid-August 1983.

of Illinois at that time.

Item 5 All documents related to the NRC staff's evaluation of recent Japanese test the core spray distribution for BWR's.

Response to Item S The following document is enclosed:

29, 1983 Memorandum from R. J. Mattson (NRC) to T. Speis (NRC) dated March l

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