ML20040H240

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Affidavit of Tg Dunning Re Contention 2 & NRC Acceptance of Applicants Analysis of Atws.Analysis Did Not Rely on Rept 1.Prof Qualifications Encl
ML20040H240
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/12/1982
From: Dunning T
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18023A006 List:
References
NUDOCS 8202170487
Download: ML20040H240 (6)


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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, Docket Nos. 50-445

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50-446 (Comanche Peak Steam Electric

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Station, Units 1 and 2)

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AFFIDAVIT OF THOMAS G. DUNNING I, Thomas G. Dunning, being duly sworn, do depose and state:

Q1.

By whom are you employed, and what is the nature of the work you perform?

A1.

I am employed as a Section Leader by the Instrumentation and Control Systems Branch (ICSB), Division of Systems Integration, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. A complete description of my professional qualifications is attached to this affidavit.

Q2. What is the nature of the responsibilities you have regaroing the Comanche Peak Steam Electric Station ("CPSES")?

A2. Section 7 of the Safety Evaluation Report ("SER") for the Instrumen-tation Control Systems for the CPSES was prepared under my direction.

Q3. Would you describe the scope of the subject matter addressed in your affidavit?

F2H2170487 EM20212 PDR ADOCK 05000445 O

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. A3.

I have been asked to address Contention 2, which alleges that:

One or more of the reports used in the construction of computer codes for the CPSES/FSAR have not been suitably verified and formally accepted; thus con-clusions based on these computer codes are invalid.

In particular, I have been asked to determine if the facts presented in paragraph 3 of the Applicants' " Statement of Material Facts For Which There Is'No Genuine Issue Regarding Contention 2" (" Statement of Material Facts"), concerning the Staff acceptance of Applicants' analysis of anticipated transient without scram ("ATWS") is correct, and if Staff supports Applicants' position.

I have also been asked to address whether Report 1, WCAp-7706, has been accepted by the Staff; whether the Sti.ff relied upon Report in its evaluation of the CPSES FSAR; and if the topical report constructs and provides verification for any computer codes.

Q4. Do you agree with paragraph 3 of the Applicants' Statement of Material Facts, with regard to the NRC Staff acceptance of Applicants' analysis of anticipated transient sequences, based on Report I?

A4.

I agree with the Applicant's Statement of Material Facts to the ex-tent that NRC Staff has accepted Applicants' analysis. However, as I state in my answer to Question 7, the Staff did not rely on Report 1 in reaching its safety conclusions in SER Section 15.3.9, and Supplemental SER ("SSER") Section 15.3.9.

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- Q5. Please describe the subject matter of Report 1.

AS. Report 1, WCAP-7706, "An Evaluation of Solid State Logic Reactor Protection in Anticipated Transients," (February 1973), was sub-mitted to the NRC Staff by Westinghouse Electric Corporation 4

(" Westinghouse"). The report provides a Westinghouse reliability analysis of the Reactor Protection System which utilizes solid state logic. Through the use of fault tree techniques, an assessment of the probability of system failure in anticipated transients is evaluated for random component failures. A qualitttive assessment of common mode failures is included. The CPSES Final Safety Analysis Report

("FSAR") references Report 1 in Sections 7.1.3.7 and 7.2.2.2.3.

This report is not concerned with the construction or validation of any computer code.

Q6. Was Report 1 accepted bv the Staff?

A6. Report I has not been accepted by the Staff.

Q7. Was Report I relied upon by the Staff in evaluating the solid state protection system for CPSES, as described by Applicants in Sections 7.1.3.7 and 7.2.2.2.3 of the CPSES FSAR?

A7. The Staff position and evaluation of the Anticipated Transient Without Scram (ATWS) issue is addressed in the CPSES ("SER")

Section 15.3.9, Appendix A, Section A-9 of the SER, and t

Section 15.3.9 of the SSER. The Staff's conclusion in the SER and SSER that the design of the solid state protection system for CPSES

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4 cont 6nns to opplicibie regulatory requirements was based upo ' an evaluation of ti'r. design that did not rely on Report 1.

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

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Thomas G. DiMning Subscribed and sworn to before me this/2 A day of February,1982.

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/>N My Comission expires:

THOMAS G. DUNNING PROFESSIONAL QUALIFICATIONS INSTRUMENTATION AND CONTROL SYSTEMS BEANCH DIVISION OF SYSTEMS INTEGRATION I have been employed by the Nuclear Regulatory Comission since November 1976.'l,

From June 1979 to the present time, I have been a Section Leader in the Instrumentation and Controls Systems Branch, Division of Systems Integration.

j Prior to ny present assignment. I' served as a Senior Engineering Systems Analyst in the Plant Systems Branch " Division of Operating Reactors.

I have participated in the review of instrumentation, control, and electrical systems of numerous nuclear power stations and in the formulation of related standards and Regulatory Guides.

I am duly registered as a Professional Engineer in Contml Systems Engineering in the state of Californt&, holding Certificate No. 752 conferred the.13th day of October 1976.

L The Instrumentation and Control Systems Branch performs an indepth technical review of the design, fabrication, qualification, and operation of nuclear power plant instrumentation and control systsms important to safety. This review includes a comprehensive assessment of the systems for all power reactors, for adherence to appropriate codes and standards iglementing the Comission's requirement and encompasses the co@lete evaluation of the applicant's safety analysis reports, generic topical reports, and other design information.

Further, the Branch develops the bases for Regulatory. Guides for instrumentation and control systems designs; evaluates experience obtained-during the construction and operation of nuclear power plants'and relates this information to future evaluations and acceptance criteria; and participates in the development of Regulatory Guides and regulations pertaining to instrumentation and control systems and other systems in the Branch area of responsibility. As a Section

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THOMAS G. DUNNING

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Leader. I supervise the work of six staff members in carrying out the responsibilities of the Branch.

I hold a Bachelor of Science degree in Electrical Engineering and a Master of Science degree in Nuclear Engineering which were conferred by the University of Wisconsin; Madison, Wisconsin. In addition I have taken post graduate courses in controls systems analysis as well as specialized training in nuclear power plant design and operations, engineering analysis, and fire protection.

My nuclear engineering experience background derives from ny current employment at the Nuclear Regulatory Commission and at General Atomic Company, San Diego, California from June 1960 to November 1976. While assigned to the Division of Operating Reacters I participated in the review and evaluations of instrumentation and control systems design changes for operating reactors.

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addition, I was assigned as a group leader in a team review effort of fire I

hazards analysis reports, including onsite inspections for 13 operating reactors.

During the 16 years plus at General Atomic I held various positions in the area of instrumentation and control systems design for High Tenperature Gas Cooled Reactors. I was involved in the preparation of specifications for radiation and process monitoring and control systems for the Peach Bottom Unit I nuclear plant and subsequently spent two years as a startup engineer at this facility.

On the Fort St. Vrain project I was assigned as a Section Leader for the NSSS process control systems and was responsible for the analysis, design and

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1 specifications for control and protection systems. This work included safety c

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l analysis and equipment qualification of safety systems in support of operating license requirements. For one year I was assigned to the Fort St. Vrain site engineering office as lead instrumentation and controls engineer, responsible for all design changes to instrumentation, control and protection systems.

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subsequently held posittens as Project Engineer for nuclear power plant projects.

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