ML20209G353

Affidavit of B Mann Supporting Applicant 860818 Motion for Authorization of Fuel Loading & Precritical Testing

ML20209G353
Person / Time
Site:	Braidwood
Issue date:	09/09/1986
From:	Mann B Office of Nuclear Reactor Regulation
To:
Shared Package
ML20209G335	List: ML20209G329 ML20209G353 ML20209G365 ML20209G377
References
OL, NUDOCS 8609120435
Download: ML20209G353 (7)

Text

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

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station, Units 1 and 2) )

AFFIDAVIT OF BERNARD MANN I, Bernard Mann, being duly sworn, depose and state:

1. I hold the position of Nuclear Engineer in the Reactor Systems Branch, Division of Pressurized Water Reactors - A, Office of Nuclear Reactor Regulation in the Nuclear Regulatory Commission (NRC). I have held that and similar positions with the NRC and the Department of Energy (DOE) since 1972. My duties include evaluation of the design, safety analysis and technical specifications of reactor systems with respect to nuclear safety during various modes of reactor operation.

2. From 1955 to 1972 I was employed by the Westinghouse Electric Corporation , Aerojet General Corporation, B attelle-Northwest , and C.F.

Braun and Company. Most of my work during this period was in the areas of nuclear systems design, analysis, project and process engineering.

3. I hold a Bachelor of Chemical Engineering degree from the University of Louisville (1948) and a Master of Science degree in Chemical Engineering from the University of Cincinnati (1940). I am a licensed 8609120435 860909 PDR ADOCK 05000456 Q PDR

professional engineer, registered in Pennsylvania (chemical engineering) and California (nuclear engineering).

4. As explained in Dr. Walter L. Brook's affidavit, the only threat to public health and safety in the performance of the proposed testing arises from inadvertent criticality in the core, which can be avoided by maintaining a sufficiently high boron concentration in the reactor coolant system. The Applicant proposes maintaining a boron concentration of at least 2000 ppm in the core and makeup water. If this concentration is maintained, Dr. Brooks concludes, based on his evaluation of calculations performed by Applicant using standard codes and methods approved by the NRC Staff, that inadvertent criticality will not occur with all rods out.

5. The Applicant has described (Affidavit of Kenneth D. Brienzo at 5 6) and committed (Affidavit of Thomas J. Maiman at i 5) to several special measures to assure that sources of unborated water will be iso-lated from the reactor coolant system (RCS) and that the boron concen-tration level in the RCS will be maintained at a level of at least 2000 ppm.

The Applicant has stated that it will provide administrative controls to assure that sources of unborated water will be isolated from the reactor coolant system by mechanically locking closed the appropriate valves.

The administrative controls the Applicant will provide to assure that the boron concentration of the reactor coolant and makeup water systems will be maintained at no less than 2000 ppm include grab samples being manually taken from the reactor coolant and makeup water systems and analyzed at least once per shift to verify that the boron concentration is at least 2000 ppm. In addition, the makeup water system will be sampled

and analyzed in this manner each time any water is added to the system to verify this concentration.

6. The Applicant has provided to the Staff tables listing the valves isolating direct unborated water sources to the reactor coolant system (RCS) (Attachment A) and valves isolating other unborated water sources (Attachment B). The Staff has reviewed the piping and instru-mentation diagrams for the chemical volume and control system and por-tions of relevant connecting systems to verify the potential flow paths that could introduce unborated water to the RCS. The Applicant has committed that it will mechanically lock closed the appropriate valves to ensure unborated water or borated water at concentration levels less than 2000 ppm will not be allowed to flow into the RCS. The Staff has reviewed these tables and has ascertained that closing the valves as indi-cated on the tables will isolate the RCS from potential flow paths that could introduce water with a boron concentration less than 2000 ppm.

The Staff will include as a license condition to any fuel loading and testing license that may be issued these tables listing the valves to be locked closed and the administrative controls under which they will be locked closed.

7. The tables provided by the Applicant indicated that there are certain valves (e.g. the demineralizer sluice water inlet and outlet isola-tion valves) which will be locked closed except for the infrequent occasions

when an activity required by plant chemistry requires the locked valve be opened for a short interval (e.g. replacement of demineralizer resin). In order to assure that water with a boron concentration level less than 2000 ppm is not inadvertently added to the RCS at those times, the Staff will require as a license condition that each time valves are manipulated, an independent confirmation of valve positions shall be made by a separate person knowledgeable of the systems being used. Further, the Staff will require as a license condition that each time valves are manipulated and water is added to the RCS the Applicant shall sample the RCS both before and after the addition of the water to determine the level of boron concentration of the water in the RCS and to ensure that the level is at or above 2000 ppm.

4 Bernard Mann Subscribed and sworn to before me t . ay of September,1986 9 Wo 4

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My mission expires: 7/1/90 1

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ATTACHMENT A VALVES ISOLATING DIRECT UNHORATED WATER SOURCES TO RCSI Valve EPN PAID / Location Tm Status J

j IVIIIB M64-4 R4 Air Operated Always Locked Closed l

ICV 8439 M64-4 C4 Manual Always Locked Closed 1CV8453 M64-4 D2 Manual Always Locked Closed ICV 8441 M64-4 B1 Manual Always Locked Closed OAD010 M65-5A D3 Manual Always Locked Closed ICV 8523A M64-6 C6 Manual Locked Closed Except When i Sluicing Demineralizer Resin 4

1CVS515 M64-6 B5 Manual Locked Closed Except When J Sluicing Demineralizer Resin ICV 8523B M64-6 C3 Manual Locked Closed Except When Sluicing Demineralizer Resin 1CV8428 M64-4 D5 Manual Always Locked Closed l

I i

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ATTACHMENT B VALVhS ISOLATING OTHER UNBORATED WATER SOURCES I. INDIRECT SOURCES OF UNBORATED WATER TO REACTOR COOOLANT SYSTEM Valve EPN P &ID/ Location Type Status 1SI8936 M61 E7 Manual Always Locked Closed ISI8031 M61 D7 Manual Locked Closed When RWST is Making Up to RCS ICV 8434 M64-4 D4 Manual Locked Closed When RWST is Making Up to RCS OAB8494 M65-5 A F3 Manual Locked Closed When Boric Acid Batch Tank is Discharging 2AB8629B M65-1B A3 Manual Always Locked Closed OAB009B M65-2A E6 Manual Always Locked Closed

. OAB8557B M65-2 A E4 Manual Always Locked Closed OAB023B M65-2A E3 Manual Always Locked Closed 1

CAB 8563A M65-2B D4 Manual Always Locked Closed 2AB023 M65-2C C8 Manual Always Locked Closed 2AB8551 M65-2C 08 Manual Always Locked Closed i 2CV8553 M65-2C D7 Manual Always Locked Closed 2AB022 P165-2 C C7 Manual Always Locked Closed s

• 2PS142 M140-5 E8 Manual Always Locked Clo%ed *

• 1 AB8629A M65-1B A3 Manual Locked Closed Execpt During OB IIUT Ma:ceup to RCS 1CV8553 M65-2C D7 Manual Locked Closed During OB Hut Makeup to RCS 1AB8551 M65-2C D7 Manual Locked Closed During OB liut Makeup to RCS

ATTACHMENT B (Cont.)

II. OTHER CONSERVATIVE ACTIONS Valve EPN PalD/ Location Type Status 1BR7053 M64-6 B8 Manual Always Locked Closed 1BR7054 M64-6 B7 Air Operated Always Locked Closed 2AB8468 M65-5A B6 Manual Always Locked Closed 2AB8465 M65-5A B4 Manual Always Locked Closed 1Ril004C M62 F5 Manual Locked Closed Except When Shell Side Vent is Locked Closed IRil004D M62 C6 Manual Locked Closed Except When Shell Side Vent is Locked Closed 1 008A M64-4 B8 Manual Locked Closed Except When

- Shell Side Vent is Locked Closed ICV 032A M64-5 B2 Manual Locked Closed Except When Shell Side Vent is Locked Closed ICV 032B M64-5 D2 Manual Locked Closed Except When Shell Side Vent is Locked Closed ICV 8537A M64-6 B6 Manual Locked Closed Except When Sluicing Demineralizer Resin ICV 8521 M64-6 AS Manual Locked Closed Except When Sluicing Demineralizer Resin ICV 8527B M64-6 B4 Manual Locked Closed Except When Sluicing Demineralizer Resin OAB8618A M65-3 E3 Manual Always Locked Closed OAB8618B M65-6 E3 Manual Always Locked Closed 1