ML20028C940
| ML20028C940 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/12/1983 |
| From: | Lefave W, Rowsome F, Turovlin B Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20028C925 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8301140328 | |
| Download: ML20028C940 (21) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COWtISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-247-SP I
CONSOLIDATED EDISON COMPANY OFNEWYORK(IndianPoint, Unit 2) 9 50-286-SP l)
POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point,-Unit 3)
)
NRC STAFF TESTIMONY OF WILLIAM T. LEFAVE,
FRANK R0WSOME AND BERNARD TUROVLIN ON CONTENTION State your name and position with the NRC.
Q.I.
I am employed by the Nuclear A.
My name is William T. LeFave.
Regulatory Commission as a Senior Auxiliary Systems Engineer in th Auxiliary Systems Branch of the Division of Systems Integration, Office of Nuclear Reactor Regulation.
Have you prepared a statement of professional qualifications?
Q.2.
A copy of my professional qualifications is attached.
A.
Yes.
What are your. review responsibilities regarding the Indian Point, Q.3.
Units 2 and 3.
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8301140328 830112 PDR ADOCK 05000247 T
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-I am responsible for the review and evaluation of those sys
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h Auxiliary Systems A.
the Indian Point Plant Units 2 and 3 for which t e h Division Branch has primary responsibility as needed either by t e hich is of Licensing or by the Division of Safety Technology, w ft Study. To currently reviewing the Indian Point Probabilistic Sa e y ling y
date, the scope of my review has included the component co f
l d t r system. For system, service water system and the auxiliary fee wa e t
including this testimony my review covered the service water sys em, l
the supply to and from the containment air coolers.
?
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Mr. Rowsome please state your name and position with th Q.4.
I am Deputy Director of the My name is Frank H. Rowsome, 3rd.
Division of Risk Analysis in the Office of Nuclear Regulator A.
Research.
?
Have you prepared a copy of your professional qualificati Q.5.
d to this Yes, a copy of my professional qualifications is attache A.
testimony.
Mr. Turovlin please state your name, position and genera Q.6.
responsiblity with the NRC.
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My name is Bernard Turovlin.
I am a Corrosion Engineer in the.
Chemical Engineering Branch of the Office of Nuclear Reactor I am responsible for Regulation, Nuclear Regulatory Commission.
safety review and evaluation of the corrosion of materials used in the construction and operation of nuclear power plants.
Have you prepared a copy of your professional qualifications?
Q.7.
Yes, a copy of my professional qualifications is attached to this '
A.
testimony.
What is the purpose of this testimony?
Q.8.
The purpose of this testimony is to address Contention 2.2(a) which A.
"The cooling system at the plants should be changed so
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provides:
This chance is that it no longer uses brackish Hudson River water.
needed to combat safety-related corrosion problems."
Mr. Rowsome, what is your summary view of the contention?
Q.9.
I do not believe that public health and safety considerations A.
warrant changing any of the cooling systems at Indian Point that now Therefore, I do not believe that the NRC employ Hudson River water.
The principal incentive for changing should order such a change.
I have the cooling system is the cost of maintenance and repair.
l not assessed whether it would be cost effective to the plant owners l
to make a change in their own interest.
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O 4-Q.10. What cooling water systems employ Hudson River water?
The service water system (both its nuclear and conventional h A.
and the circulating water system utilize Hudson River water to carry n
off waste heat to the environment.
9 Q.11. What is the function of the service water system?
3 The service water system provides cooling for a wide variety of r
A.
Some of these functions auxiliary equipment throughout the plant.
are safety-related and some are not.
Q.12. What is the function of the circulating water system?
The circulating water system provides cooling water to the main A.
Waste heat from the reactor is dissipated to the condenser.
environment through the condenser during normal power gen The circulating in the early stages of a normal, gradual shutdown.
water system serves to carry off this heat.
Q.13. How might the use of Hudson River water in the circulati system affect the safety of the units?
There is no direct effect on safety associated with the use of i
A.
Hudson River water in place of other cooling water in the circ l
However, there can be indirect effects on the ing water system.
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. d to frequency of initiating events having the potential to lea In particular steam generator tube leaks may be so
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t in a plant more frequent, and transients slightly more frequen l ting water.
employing Hudson River water in place of other circu a Q.14. How important to safety is the effect on the freque ti initiating events from the use of Hudson River water in the circulating water system?
b upture Gary Holahan is providing testimony on steam generator tu f
(Board Question 2.2.1) that will address th A.
With regard to other it relates to steam generator tube failures.
enerator effects of the use of Hudson River water, neither steam g feedwater tube deterioration nor an occasional' shutdown due to poor Generally a planned gradual chemistry has much effect on safety.
fety shutdown - which does not pose a critical challenge to sa If the disturbance is too systems - takes place in each case.
Accidents severe for a planned shutdown a spontaneous trip occurs.
ther than originating in spontaneous plant trips (that is, events o idents, loss earthquakes, storms, plant fires, loss of coolant acc it. In of offsite power, etc.) pose very little risk at either un the order of addition, plant trips are a comon event, occuring on A very slight increase in such events (caused by ten times a year.
d by Hudson a rare trip to avoid the use of feedwater contaminate ik River in-leakage) will make a negligible difference in r s.
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f).15. How does the use of Hudson River water in the service water system i
affect safety?
The systems' cooled by service water fall into three categories A.
P
- 1) Those not related to safety.
Many of the loads cooled by service water are not called upon to perform their function under upset conditions, or are not relevant to radiation safety. At most, a failure of these functions could force a shutdown. As noted above, slight i
i increases (or decreases) in the frequency of shutdowns have a negligible effect on risk.
I
- 2) Systems already isolated from brackish water, The service water system cools a number of closed loop cooling systems. The contention implies that some or all l
additional cooling loads should be similarly isolated from Hudson River water. The contention is moot for those that already are isolated, such as the loads on:
l i) the component cooling water system.
1 ii) the diesel generator jacket cooling system 1
l iii) the control room air conditioners i
iv) the instrument air aftercoolers i
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, 3) Other safety-related components directly cooled by serl.
water.
i f the These are the components we need to examine to determ l
contention as it applies to the service water system.
Q.16. What are the safety-related components in category 3?
A.
They are:
The containment air coolers with their. fan motor c 1)
The diesel generator lubricating oil coolers.
2)
Q.17. Were failures in these components included in th of risk and/or in the licensees' IPPSS?
d Yes, both failures in service, and unavailability due to test A.
maintenance were considered in both PRA's for I
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Q.18. Do random failures of the containme dies?
generators contribute significantly to the risk in these stu The risk is dominated by accident mechanisms that A.
No, they do not.
These l
defeat almost all of the active safety functions at once.
mechanisms include earthquakes and the events that des l
communication of the control building with the rest of the
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- ~ w..a f1 8-l (some in-plant fins, and for Unit 2, some particularly severe stoms). Randomly occuring failums in individual safety components, of the kind that might be caused by corrosion in the heat exchangers served by Hudson River water, have negligible l
importance to risk, because a great many such failures and others l
as well would have to occur at the same ' time to cause a severe accident.
Q.19. Mr. I.eFave, in light of the past events at Indian Point Unit 2, namely that 9 feet of the reactor vessel became submerged in the brackish service water due to containment air cooler leakage, do you believe that the use of Hudson River water raises a safety concern?
I do not believe that there is a safety concern due to containment A.
There-air cooler leakage regardless of the cause of the leakage.
fore, I believe that the use of Hudson River water presents an As identified in our safety economic rather than a safety concern.
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evaluation of May 8,1981 regarding the failure of the cont 31nment air coolers at Indian Point Unit 2 and our restart safety evaluation for Unit 3 of November 13, 1980, design modifications, procedural changes, and revisions to Technical Specifications and Surveillance Requirements have been made for each unit to prevent recurrence of the October 17, 1980 flooding event (containment air cooler leakage) at Indian Point, Unit 2.
Specifically, the leak detection in the containment buildings has been upgraded as 4
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identified in A22 through A27 below, such that the leakage be detected and isolated prior to the accuciulation of water to Also, the Technical degree that would cause a safety concern.
tion Specifications require plant shut:fown if redundant leak dete ble.
is not available or if the containment air coolers are not opera lly The containment air coolers are also required to be periodica I.
leak tested and repaired if the leakage rate exceeds a certa amount.
h iver 0.20. Has the licensee considered revising the design to exc iga water from being used in the containment buildings and us n closed cooling water s.vstem design instead?
In January 1981, Bechtel Power Corporation completed i
f Yes.
for the licensee entitled " Feasibility Study for the Modifica t A.
This report Containment Cooling System for Indian Point Unit 2."
considered seven possible variations in design that did not us
- tions, service water for containment air coolers during nonnal opera during and, for some of the designs, did not use service water emergency conditions.
Q.21. Has the licensee committed to installing one of th designs?
11, 1982, it i
In the licensee's most recent letter of February A.
No.
f the was stated that a review of the detailed design of one o
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-..,. -.. _.. alternatives (" hybrid" closed-loop cooling system) that appeared most feasible was completed and compared with the present design.
The licensee was not convinced that the more complex " hybrid" design should be installed and stated that the review of the " hybrid" and other alternatives was continuing, and that future actions would be guided by the perfomance of the present system and the results of the surveillance program on the fan cooler units and service water piping.
i Q.22. Why doesn't the Staff require such a design change rather than wait for the licensees to make a decision?
With the new modifications at both units, which included new contain-A.
ment air coolers and the installation of Copper-Nickel service water l
piping in the containment at Unit 2, any significant leakage that occurs would be discovered in a timely manner and would result in repairs or plant shutdown, as indicated in the Technical Specifica-Therefore, we believe that since no safety-related equip-tions.
l ment will be affected, other than the loss of the leaking air l
At Indian l
cooler itself, safe shutdcwn will not be precluded.
f Point Unit 3, five fan motor cooler units have been replaced as of i
November,1980 after leakage was experienced up to approximately 2 l
This demonstrates the adequacy of the leak detection methods.
j If frequent leakage continues, the plant will spend a large amount f
gpm.
of time in a shutdown condition, thereby imposing an economic l
penalty on the utilities.
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ih Q.23. Is the Staff doing anything in the long term on a g blem?
. regard to the Indian Point service water pro NRC has two generic tasks that are directly related to thea
. Yes.
'A.
The first leakage problem that occurred at Indian Point, Unit 2.
l ification of thcse is Item II.F.1 Attachment 5 of NUREG-0737, "C ar
{l This item, which deals with
- r of the TMI Action Plan Requirements."
[l l being containment sump-level monitoring equipment, is current y f
Our safety evaluation of b
evaluated for Indian Point Units 2 and 3.
A second generic task this item for both units is soon to be issued.
d at all under staff review deals with generic resolution of concerns
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ts. All plants that havs service water piping inside their conta nme be applied generic requirements that result from this study will also This task will probably result in require-to thp Indian Point Units.
ifications ments for special surveillance, testing and technical spec for all plants with designs similar to Indian Point.
t Q.24. What changes have been made to the containme at what new equipment has been installed in the containment sum Indian Point Unit 2 to prevent a recurrence of the Octobef l
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flooding event?
d The license has replaced all containment air coolers with i
The A.
units that allow access for tube repairs and tube plugg ng.
i existing service water isolation valves to the containment a the coolers have been replaced with an improved design to e Magnetrols have leakage problem experienced with the old valves.
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, been added to control the containuient sump pumps' start and stop levels to eliminate problems associated with the original float-type A remote control station (on, auto, off) has been added controls.
l Previously, there was just a local control to the control room.
Separate independent power supplies have been provided fo station.
Ontinuous level the sump pumps and the reactor cavity pumps.
indication with alarm and record has been provided for the Instrumentation to containment sump (a post-TMI requirement).
monitor discharge flow, discharge water chemical hardness and temperature have also been added.
i A flood-level switch in the RHR suction line compartment of the sump has been added and the TV camera has been focused to The con-accumulations on the 46 foot containment floor elevation.
tainment floor at the 46 foot elevation overflows to the rea cavity when the water reaches 2 to 4 inches above the floor at Unit 2 and 51 inches at Unit 3.
Q.25. Have other features been added or modified, in addition to c in the containment sump?
The recirculation sump in the containment will now be kept dry f
A.
Yes.
instead of flooded allowing the two lowest level lights (previousl This is an improvement because always lit) to be used for alarms.
now the plant operators will receive information that both the containment and emergency recirculation sumps fill with water be f
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.g the reactor cavity begins to flood. Continuous level indication has also been added to the recirculation sump and to the reactor cav'ity as a result of TM1 Item II.F.1 The reactor cavity TV camera is now-7 l
focused on the low point of the curb to provide immediata indication of water, and an alarm of the lowest switch position on one of the l has been.added. The reactor cavity l
'two pump control magnetro s pumps have been improved with an open pipe / funnel anti-siphoning device in the discharge line at the containment sump, separate power 1
supplies, and submersible level control switches, including loss of i
suction head protection and equa'lized running hours.
Q.26.NhatimprovementshavebeenmadeatUnit3?
l At Unit 3, a new capacitive detector device has-been added to A.
detect approximately 1 inch of water on the 46 foot containment This allows I
floor elevation, with an audible control room alam.
l early detection of the containment sump overflowing to the con-Two new pumps have been installed in the reactor tainment floor.
f cavity which will not operate in such a way as to be subject to trips on thermal overload, as might have been the case with the A column measuring device has been installed in previous pumps.
the cavity that will activate two independent audible alarms in the control room when approximately 1 inch and 3 inches of water are in A search has been conducted for siphon the bottom of the cavity.
paths into the reactor cavity, resulting in sealing of one conduit 4
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_ Q.27. What existing features does Unit 3 have such that ma
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type modifications are not necessary?
'l The design and manufactured features of the containment air cool A.
at Unit 3 are different than those at Unit 2 allowing easier At Unit 3 there have been no leaks in the piping maintenance.
associated with the fan coolers (such as the main contributing lea Unit 3-to the Unit 2 event in a 10 inch service wcter return pipe).
has used "hard" solder patches to build up a patch over several
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small leaks that have proven more satisfactory than the "episeal or " adams clamp" patches that had been used on the Unit 2 coolers Technical specifications at Unit 3 already existed that required testing of the air cooler system that limited the leak rate to O.36 gallons per minute, this leakage limit includes all valves, At Unit 3, the coils and pipes, not just the isolation valves.
recirculation sump was normally kept dry which is now also done Unit 2 to allow two additional level detectors in that sump to be Also one of the two level indicating detectors in each useful.
sump must be operable by Unit 3 technical specifications for continued plant operation.
Q.28. Do you feel that leakage caused by corrosion in the conta air coolers warrants a requirement of a closed loop design for Indian Point Units 2 and 37
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_ The Staff should require a design change only if it appears A.
No.
that safe shutdown'would be precluded in the event of a'failurei Because of the modified detection equipment because of corrosion.
and new surveillance requirements and plant technical specificati described above and previously evaluated.there is little concern that a sudden catastrophic failure of the service water system due to corrosion could prevent safe plant shutdown.
Further, the modifications made (as described above in answer to Questions 22 through 27) would prevent a small leak from ' d into a significantly large leak.
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PROFES5IONAL QUALIFICATIONS FRANK'H. a0W50ME. 3rd Atony M IssIOn
'u s nuCLEAn Resut i ion of Risk Analysis in' i
I'an Frank H. Rowsome. 3rd. Deputy Director of the D v sI the Office of Nuclear Regulatory Research.The work en
. joinirg the NRC in July 1979.Huch of the work of the Division is
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i and staffing the Division.
The remainder entails risk research in reactor accident risk assessment.
clear fuel cycle and to h
assessment applied to non-reactor aspects of t e nu risk.
standards development related to system reliability or l
d in 1962.' I studied I received a bachelor's degree in physics from Harvar mentsforaph.
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theoretical physics at Cornell, completing all requ r l
for the dissertation in 1965.
ities.
in theoretical physics at several colleges and univers engineer. fty initial.
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l In 1973 I joines the Bechtel, power Corporation as a nuc ei assignment was. so perform accident analyses for nuc e formed group of systems l
l After six menths in that job. I was transferred to a new ybilityl
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engineers charged with developing for Bechtel a capai d the N l
ments and system reliability analyses of the k n f med reliability the Reactor Safeyltg. In that capacity I per orograms for syste I
nuclear plant safety systems developed computer prbility data i
analyses, perfonr.ed analyses of component relia ces. 'I progressed from l
analyses, and event tree analyses of accident sequenleader nuclear engineer to senior engineer, to grcup In this last positir a in 1979.
Supervisor before leaving Bechtel to join the NRC ing economics, reliability i
at Bechtel. I supervised the application of eng neer 6
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Paga 2 Frank H. Rowsome. 3rd Professional Qualifications (Cont.)
engineering, and analysis techniques to power plant availabiljty optimizl I
as well as nuclear safety analysis.
. While serving as Deputy Director of the Division of Risk Analysis (and its anticedent, the Probabilistic Analy' sis Staff). I also served as Acting Director (7 months), acting chief of the Reactor Risk Branch (9 months) and a of the Risk Methodology and Data Branch (4 monti.s).
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l This experience has given me the practitioner's view as well as the man l
view of those facits of reactor risk assessment entailing the classification I
reactor accident sequences, system reliability analysis, human reliability f
I analysis, and the estimation of the likeithood of severe reactor accidents.
have the manager's perspective but not the practit'ioner's experience with l
those facits entailing containment challenge analysis, consequence analysi l
and risk assessment applied to other parts of the nuclear fuel cycle.",
My role in the development of testimony for this hearing has been as j
j of the preparation of testimony on risk and one of the coordinators of the l
listic Safety Study."
, technical critique of the licensee's " Indian Point Probabi I am not an expert on the design or operation of the Indian Point plants.
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58 List of Publications _
in Power Plant Design "
i "The Role of System Reliability Predict onF.H.
1977.
8:
1 lt Tree Analysis?' by 1.
Nuclear Society / Canadian "How Finely Should Faults be Resolved in F 18, 1976.
y i
3 2.
Nuclear Association Joint Meeting in Toron ome III. U.S. Nuclear "The Role of IREP in NRC Programs" F.H. Rows 20555.
Regulatory Comission, Washington, D.C.
r System," F.H. Rowsome, III, 3.
d
" Fault Tree Analysis of an Auxiliary Fee wate Division,F 77 805-5.
Bechtel Power Corp., Gaithersburg Power 4.
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WILLIAM T. LEFAVE PROFESSIONAL QUALIFICATIONS AUXILIARY SYSTEMS BRANCN DEVISION OF SYSTEMS INTEGRATION OFFICE OF NUCLEAR REACTOR REGULATIO sponsible for the I an a Senior Auxiliary Systems Branch ingineer and en ree t
safety review of auxiliary systems and associated fea urTh and operating procedures for nuclear power plants.lth and reviaws is to assure no undue risk to the hea in 1964 with an Associate I graduated from Massachusetts Bay Comunity of Science Degree in Electronics.
5W. submarine thru new cons power schools and was a reactor operator o tion' and while at sea.
1 i
with a Bachelor of Science in Nuclear Engineer ng.
l iliary Systems Branch of In October of 1973 I accepted a position with the Aux the Atomic Energy Commission and have remaine f N clear Reactor Regulation.
of the Division of Systems Integration,. Office,o _ u iliary system reviews During these years I-have been responsible for the aux of the following construction permit, prelimi j
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licenseapplicationIs Units 1 & 2; Feral Unit 2!
Units'1 & 2; Midland Plant Units l'8 2; Susquehanna,N i
RESAR 41. 35 and 414; GESSAR-238 and 251; Float n and Wolf Creek; GISBSAR; Erie 1 & 2; Farl and Pebble Springs 1 & 2.
iliary fe'edwater system for the review of the Indian Point Units 2 & 3, auxdix R re reliability evaluation (THI. Item II.E.1.1), Appen t cooling water.
Probabilistic Eafety Study as it relates to the compo service water and auxiliary feedwater systems.
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.2-e Br nchds t revisions of the Adx111ary System the initia1' development and recen Sections 9.2.1. "Strylce Water f B sections including:
j Standard Review Plan Water System."
System" and 9.2.2, " Component Cooling e
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1----______
SERNARD TUROVLIN PROFES$10NAL ENG1R ER - CALIFORNIA #9180 MAY. IM9 4
I am.a Corrosion Engineer in the Chemical Engineering Branch of the I-Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission.
l am responsible for safety reviaw and evaluation of the corrosion of materials used in the construction and operation of nuclear power plants.
I received a Bachelor of Science degree from the University of Illinois in 1941.
I have been assoc.tated with nuclear energy development and construction as an engineer or metallurgist since 1942.
I have been employed in these capacities by numerous organizations beginning with the Metallurgical Laboratory of the University of Chicago transferring to Los Alamos Laboratory, Brockhaven National Laboratory, Combustion Engineering Inc.,
General Atomic, General Dynamics /Convalr. U.S. Army Nuclear Power Group.
I have spent a minimum of 4 years at each location.
I have been responsible for the development of basic fabrication techniques, non-destructive examination, and failure analysis.
j I have done. engineering design and component testing for various components l
l used in the nuclear energy field.
I have more than 15 patents for various components and techniques used in the above field.
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