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Category:AFFIDAVITS
MONTHYEARML20234D0961987-07-0101 July 1987 Affidavit of DW Cassel.* Affidavit Re Intervenors Rorem,Et Al Motion to Reopen Record to Admit Late Filed Contention on Financial Qualification.Related Info Encl.W/Certificate of Svc & Svc List ML20214N0521987-05-28028 May 1987 Affidavit of Mj Wallace.* Affidavit of Mj Wallace Re Startup & Initial Criticality of Unit 1.W/Certificate of Svc ML20214N0471987-05-28028 May 1987 Affidavit of Jc Bukovski.* Affidavit of Jc Bukovski Re Delay in Startup,Testing & Commercial Operation of Unit 1 ML20205R9981987-04-0101 April 1987 Affidavit of Jt Louden Re Review of Lk Comstock Welding Procedures,Including Specs & Supporting Procedure Qualification Records in Effect from 841109-851231.Joint Welding Procedure Specs Encl ML20205R9661987-04-0101 April 1987 Affidavit of at Simile Re Insp of Lk Comstock Files of Superceded Revs to Welding Procedures & Current & Past Procedure Qualification Records for Period of 841109-851231 ML20211H4661986-10-27027 October 1986 Affidavit of Nondisclosure of RO Wolf Re 851206 Protective Order.Certificate of Svc Encl ML20209G3531986-09-0909 September 1986 Affidavit of B Mann Supporting Applicant 860818 Motion for Authorization of Fuel Loading & Precritical Testing ML20209G3771986-09-0909 September 1986 Affidavit of Rn Gardner Re Region III Intent to Ensure Compliance W/License Conditions Invoked by License Issued as Result of Motion for Authorization of Fuel Loading & Precritical Testing.Certificate of Svc Encl ML20209G3651986-09-0808 September 1986 Affidavit of Wl Brooks Supporting Applicant 860818 Motion for Authorization of Fuel Loading & Precritical Testing ML20203L1741986-08-19019 August 1986 Affidavit of Rj Slember Supporting Applicant Motion for Authorization for Fuel Loading & Precritical Testing. Certificate of Svc Encl.Related Correspondence ML20214K7611986-08-18018 August 1986 Affidavit of Kd Brienzo Re Special Measures for Fuel Loading & Precritical Testing Activities ML20214K7761986-08-18018 August 1986 Affidavit of Tj Maiman Supporting Util Request for Authorization for Fuel Loading & Precritical Testing. Rj Slember Unexecuted Affidavit Encl.W/Certificate of Svc ML20199K8871986-07-0101 July 1986 Affidavit of KT Kostal in Response to Motion to Admit Late Filed Contention on Overstress of Structural Columns. Controlled Program Implemented to Assure That Structural Steel Not Overstressed.Certificate of Svc Encl ML20203N1331986-04-29029 April 1986 Affidavit of Ds Hefter Ack Receipt & Understanding of Encl Agreed Protective Order Re Protected Info ML20141D7981986-04-0202 April 1986 Affidavit of Tj Maiman Re Braidwood Unit 1 Scheduled Fuel Load Date ML20140C6891986-03-20020 March 1986 Affidavit of Mi Miller Re Preparation for Evidentiary Hearings on Contentions 1.A,6.A,10.A,12.A,13.A,10B & 11C. W/Certificate of Svc.Related Correspondence ML20140D6841986-03-20020 March 1986 Affidavit of Mi Miller Re Torrey Pines Technology,Inc Reinsp of safety-related Mechanical Equipment.Factual Matters in Marcus Assessment Have Not Been Withheld from Discovery Process.Certificate of Svc Encl ML20214C5261986-02-15015 February 1986 Affidavit of Wj Kropp Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 10F.Related Info Encl ML20214C4391986-02-13013 February 1986 Affidavit of Rd Schulz Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 6.G.Related Info Encl ML20214C3301986-02-13013 February 1986 Affidavit of Jm Jacobson Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 3.C.Related Info Encl ML20214C3341986-02-13013 February 1986 Affidavit of JW Muffett Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 5.A.Related Info Encl ML20214C5141986-02-13013 February 1986 Affidavit of Kd Ward Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 9.D.Related Info Encl ML20214C3801986-02-13013 February 1986 Affidavit of JW Muffett Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 5.C.Related Info Encl ML20214C6761986-02-13013 February 1986 Affidavit of JW Muffett Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.4.Supporting Documentation & Certificate of Svc Encl ML20214C6281986-02-13013 February 1986 Affidavit of Rd Schulz Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.3.Supporting Documentation Encl ML20214C6061986-02-13013 February 1986 Affidavit of Pr Pelke Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.2.Supporting Documentation Encl ML20214C5961986-02-13013 February 1986 Affidavit of Rd Schulz Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.1.Supporting Documentation Encl ML20214C5831986-02-13013 February 1986 Affidavit of JW Muffett Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 13.B.Supporting Documentation Encl ML20214C5801986-02-13013 February 1986 Affidavit of Rn Gardner Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 12.J.Supporting Documentation Encl ML20214C5691986-02-13013 February 1986 Affidavit of Rn Gardner Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 12.F.Related Info Encl ML20214C5521986-02-13013 February 1986 Affidavit of Rn Gardner Supporting Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 12.E.Related Info Encl ML20214C4961986-02-13013 February 1986 Affidavit of Kd Ward Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 9.C.Related Info Encl ML20214C4681986-02-13013 February 1986 Affidavit of Jm Jacobson Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 9.A.Related Info Encl ML20214C4511986-02-13013 February 1986 Affidavit of Rd Schulz Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 6.I.Related Info Encl ML20214C3581986-02-13013 February 1986 Affidavit of Wj Kropp Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 5B.Related Info Encl ML20214C4091986-02-13013 February 1986 Affidavit of Rd Schulz Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 6.F.Related Info Encl ML20137A9131986-01-15015 January 1986 Affidavit of J Gallo Re 851206 Protective Order.Receipt of Order Ack.Protection from Discrimination Emphasized for Util Employees Participating in Proceedings.Related Correspondence ML20137J1251986-01-10010 January 1986 Affidavit of Ld Butterfield Re Respiratory Protection. Statement Re Use of Handkerchief Deleted from Emergency Planning Brochures Due to Technical Inappropriateness. Certificate of Svc Encl.Related Correspondence ML20138M6501985-12-19019 December 1985 Affidavit of Mj Wallace Re QA Contention Concerning Util Responsiveness to QA Audit Findings & NRC Noncompliance & Nonconformance Repts.Corrective Actions Implemented on Schedule to Achieve Fuel Load Date.W/Certificate of Svc ML20138P5391985-12-18018 December 1985 Affidavit of G Wegner Re Rorem Offer of Proof.Certificate of Svc Encl ML20138N5011985-12-18018 December 1985 Affidavit of G Wenger Re Rorem Offer of Proof Concerning Seven Issues Questioning Whether Certain Subjs Adequately Addressed by State of Il Plan for Radiological Accidents ML20137X1001985-12-0202 December 1985 Affidavit of Js Fairow Re Seven Emergency Planning Issues Raised by Intervenor 851025 Offer of Proof.Certificate of Svc Encl ML20137C3121985-11-20020 November 1985 Affidavit of Rv Seltmann Supporting Revised Responses to Rorem Interrogatories 13-16 & Contention Item 6.B.5 Re Qa. Related Correspondence ML20137C3291985-11-20020 November 1985 Affidavit of If Dewald Supporting Revised Responses to Rorem Interrogatories 13-16 & Contention Item 6.B.5 Re Qa.Related Correspondence ML20137C3421985-11-20020 November 1985 Affidavit of TE Quaka Supporting Revised Responses to Rorem Interrogatories 13-16 & Contention Item 6.B.5 Re Qa.Related Correspondence ML20133F5361985-10-0808 October 1985 Affidavit of Jg Keppler Re 850621 Util late-filed Amended QA Contention.Certificate of Svc Encl ML20133F5971985-10-0202 October 1985 Affidavit of Rv Seltmann Supporting Util Response to Specific Interrogatories 58 & 59 Filed by Intervenor as Part of QA Contention.Related Correspondence ML20132C4381985-09-23023 September 1985 Affidavit of Mj Wallace Re Impact of Intervenor QA Contention on Project Const.Critical Path Activities Delayed 3 to 4 Months by QA Contention.Continued Litigation Will Delay Const Further & Elevate Cost ML20133F5931985-09-19019 September 1985 Affidavit of JW Gieseker Supporting Util Response to Specific Interrogatories 58 & 59 Filed by Intervenor as Part of QA Contention.Related Correspondence ML20133F6001985-09-0606 September 1985 Affidavit of DA Hoffer Supporting Util Response to Specific Interrogatories 58 & 59 Filed by Intervenor as Part of QA Contention.Certificate of Svc Encl.Related Correspondence 1987-07-01
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20149H0301997-06-19019 June 1997 Comment Opposing Proposed Generic Communications Re Control Rod Insertion Problems ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20204G3081988-10-19019 October 1988 Order Imposing Civil Monetary Penalty in Amount of $50,000, Per 880506 Notice of Violation from Insp on 880301-17 ML20154K0301988-05-20020 May 1988 Transcript of 880520 Dicussion/Possible Vote in Rockville,Md Re Full Power OL for Facility.Pp 1-70.Related Info Encl ML20148G2161988-03-25025 March 1988 Decision.* Affirms Concluding Partial Initial Decision, LBP-87-14,25 NRC 461.Served on 880325 ML20149D8231988-02-0101 February 1988 Notice of Withdrawal.* Withdraws Appearance as Atty for Util in Proceeding,Effective 880201.Certificate of Svc Encl ML20236A8341987-10-21021 October 1987 Transcript of 871021 Proceedings in Bethesda,Md.Pp 1-100 ML20235K8741987-09-30030 September 1987 Notice of Oral Argument.* Oral Argument on Pending Appeal of Intervenors Bridget Little Rorem from Board 870519 Concluding Partial Initial Decision in Proceeding Will Be Heard on 871021.Served on 871002 ML20235H7121987-09-25025 September 1987 Memorandum & Order.* Intervenor Appeal from ASLB Rejection of late-filed Contention Dismissed & LBP-87-19 & LBP-87-22 Vacated on Grounds of Mootness Due to Util Withdrawing Amend Application.Served on 870928 ML20237L7461987-09-0303 September 1987 Order.* Oral Argument on Pending Appeal of Intervenors Bl Rorem Et Al from Licensing Board 870519 Concluding Partial Initial Decision in OL Proceeding Will Be Heard on 871021 in NRC Public Hearing Room.Served on 870903 ML20237L7721987-09-0101 September 1987 Reconstitution of Aslab.* Notice That Aslab Has Been Reconstituted for OL Proceeding.Board Will Consist of as Rosenthal,Wr Johnson & Ha Wilber.Served on 870902 ML20237L6931987-08-28028 August 1987 Decision.* Review of Licensing Board 870513 & 0706 Partial Initial Decisions Revealed No Error Necessitating Corrective Action.Result Reached by Licensing Board Re Decision LBP-87-13 Affirmed.Served on 870831 ML20237K0361987-08-11011 August 1987 NRC Staff Brief in Support of LBP-87-14.* Certificate of Svc Encl ML20236P1101987-07-31031 July 1987 Brief of Comm Ed.* Brief Filed Re Appeal by Bridget Little Rorem,Et Al from ASLB 870519 Concluding Partial Initial Decision.Appeal Shoud Be Denied & Decision Affirmed. Certificate of Svc Encl ML20236N9791987-07-31031 July 1987 NRC Staff Response to Aslab Order of 870721.* NRC Supports Deferral of Briefing of Intervenors Appeal Until Applicant Affirmation Re Withdrawal of License Amend Application Received.Bc Hunsader Encl.W/Certificate of Svc ML20236N8851987-07-31031 July 1987 Response to Intervenors Request for Deferral of Further Appellate Proceedings.* Forwards Util to NRC Withdrawing License Amend Applications Re Ownership.Pending Appeal Should Be Dismissed.Certificate of Svc Encl ML20235Y8711987-07-23023 July 1987 Appeal from Licensing Board Denial of Motion to Reopen Record.* Intervenors Rorem Appeal from Decision of Licensing Board of 870706 Denying Rorem Motion to Reopen Record for Purpose of Admitting Late Contention.W/Certificate of Svc ML20235Y9081987-07-21021 July 1987 Order.* Date for Filing Briefs Re Intervenor Appeal of Board 870706 Memorandum & Order Denying Motion for Reconsideration & Motion to Admit late-filed Contention Postponed Until Further Order by Board.Served on 870722 ML20234D0521987-07-0202 July 1987 Motion to Reopen Record to Admit late-filed Contention on Financial Qualifications.* Record Should Be Reopened Since Rule Barring case-by-case Financial Qualification Adjudication Not Applicable ML20235D6761987-07-0202 July 1987 Order.* Intervenors 870623 Motion That ASLB Reconsider 870610 Memorandum & Order Denying 870506 Motion to Reopen Record & 870701 Motion to Admit late-filed Contention Denied.Motion in Alternative Dismissed.Served on 870707 ML20234D0961987-07-0101 July 1987 Affidavit of DW Cassel.* Affidavit Re Intervenors Rorem,Et Al Motion to Reopen Record to Admit Late Filed Contention on Financial Qualification.Related Info Encl.W/Certificate of Svc & Svc List ML20216J8821987-07-0101 July 1987 Motion in Alternative Before Appeal Board.* Intervenors Hold That Jurisdiction Over 870701 Motion to Reopen Record to Admit Late Filed Contention on Financial Qualifications Remains W/Aslb.W/Svc List & Certificate of Svc ML20234D0361987-07-0101 July 1987 Opening Brief of intervenors-appellants Bridget Little Rorem,Et Al.* Board Majority Committed Errors of Fact & Law That Compel Reversal of 870519 Concluding Partial Initial Decision.Certificate of Svc Encl CLI-87-07, Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 8707011987-06-30030 June 1987 Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 870701 ML20235A7271987-06-30030 June 1987 Transcript of 870630 Discussion/Possible Vote in Washington, DC Re Full Power OL for Facility.Pp 1-70.Supporting Documentation Encl ML20216D1941987-06-22022 June 1987 Order.* Amend to 861107 Protective Order Which Resolved Dispute Between ASLB & Commission Ofc of Investigation Over Disclosure of Certain Investigatory Matls.Certificate of Svc Encl.Served on 870623 ML20215J8891987-06-19019 June 1987 Applicant Texas Utils Electric Co Petition for Directed Certification of Licensing Board Order of 870312.* Brief Supports Granting Petition to Vacate ASLB 870312 Order. Supporting Documentation & Certificate of Svc Encl ML20215D9241987-06-15015 June 1987 Memorandum on Licensing Board Jurisdiction.* Jurisdiction Over Intervenors 870506 Motion Retained Until Further Action of Licensing Board Due to Util 870528 Filing of Application for Amend to Ol.Served on 870616 ML20214W9601987-06-12012 June 1987 Transcript of 870612 Telcon in Washington,Dc.Pp 18,585- 18,596 ML20214W5031987-06-10010 June 1987 Memorandum & Order (Denying Intervenors Motion to Admit late-filed Contentions on Financial Qualifications).* Rorem, Et Al 870506 Motion Re Financial Qualifications of New co- Licensees Denied for Want of Jurisdiction.Served on 870611 ML20214W5491987-06-0909 June 1987 Notice of Reconstitution of Board.* Iw Smith,Chairman & Rf Cole & AD Callihan,Members.Served on 870610 ML20214W4911987-06-0909 June 1987 Order.* ASLB 870513 Partial Initial Decision Addressing Emergency Planning Issues Will Be Reviewed Sua Sponte & Will Not Be Deemed Final Until Further Order.No Appeal from Decision Received ML20214P0811987-06-0101 June 1987 Notice of Appeal.* Intervenor Bl Rorem,By Attys & in Accordance w/10CFR2.762,appeal ASLB 870519 Concluding Partial Initial Decision Re Plant Which Served on Parties on 870521.Notice of Appearance & Certificate of Svc Encl ML20214N0521987-05-28028 May 1987 Affidavit of Mj Wallace.* Affidavit of Mj Wallace Re Startup & Initial Criticality of Unit 1.W/Certificate of Svc ML20214N0471987-05-28028 May 1987 Affidavit of Jc Bukovski.* Affidavit of Jc Bukovski Re Delay in Startup,Testing & Commercial Operation of Unit 1 ML20214N0421987-05-28028 May 1987 Commonwealth Edison Co Comments to Commission on Immediate Effectiveness Issues.* Forwards Affidavits of Mj Wallace & Jc Bukovski.Requests Opportunity to Be Heard If Commission Contemplates Such Stay ML20214N4321987-05-26026 May 1987 NRC Staff Response to Motion to Admit late-filed Contention on Financial Qualifications.* Board Must Deny Motion to Admit late-filed Contention & Deny Request to Certify Question of Waiver to Commission.W/Certificate of Svc ML20214N3901987-05-22022 May 1987 Amend to Concluding Partial Initial Decision.* Amends 870519 Concluding Initial Decision to Delete Limited Authorization Granted NRR to Issue License for Low Power Testing,Due to Issuance of LBP-87-13 on 870513.Served on 870526 ML20214N0631987-05-19019 May 1987 Errata Correction.* Requests Pen & Ink Corrections to Minority Decision Pages Forwarded as Corrected Pages to Errata .Pages 73,74 & 75 Should Be Numbered as Pages 72,73 & 74,respectively.Served on 870529 ML20214N0851987-05-19019 May 1987 Errata.* Forwards Corrected Pages to Minority Opinion, Matters of Dissent.Served on 870528 ML20214G5141987-05-19019 May 1987 Response to Intervenor Motion Seeking to Reopen Record for Admission of New Contention.* Intervenor Filed Motion, Motion to Admit Late Filed Contention on Financial Qualifications. Affidavit & Certificate of Svc Encl ML20214N3431987-05-19019 May 1987 Errata to Concluding Partial Initial Decision (Ol).* Minor Editoral Corrections Listed.Served on 870528 ML20214G5921987-05-19019 May 1987 Concluding Partial Initial Decision (Ol).* Due to Violation Re Discouragement to Document Any Major Deficiency That Could Result in Lengthy Delay in Production,Civil Penalty Should Be Imposed on Comstock & Util.Served on 870521 ML20214G8701987-05-18018 May 1987 Notice of Reconstitution of Aslab.Gj Edles Chairman & WR Johnson & CN Kohl Members.Served on 870520 ML20213F9971987-05-13013 May 1987 Partial Initial Decision on Emergency Planning Issues.* ASLB Resolves All Outstanding Issues Re Offsite Emergency Favorably to Applicant Subj to Certain Info Being Included in Next Emergency Info Booklet.Served on 870514 ML20215K9991987-05-0606 May 1987 Motion to Admit late-filed Contention on Financial Qualifications.* Contention Based on Util 870406 Filing Re New Ownership & Financing for Facility.Affidavit & Certificate of Svc Encl ML20214F1991987-04-22022 April 1987 Applicant Exhibit A-188,consisting of Admitting Exhibit.Util Re General Ofc Records Audit,Lk Comstock Engineering Co,Inc 830110 Memo Re Audit Responses & 821101 General Insp Rept Re Torque Wrench Test Record Encl 1999-03-02
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE-THE ATOMIC 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 THOMAS J. MAIMAN-I, Thomas J. Maiman, being duly sworn, depose and state:
- 1. I am Vice President and Manager of Projects for Commonwealth Edison Company. As Manager of Projects, I have overall responsibility for the engineering, budgeting, scheduling, construction, testing and startup of Commonwealth Edison's nuclear construction projects, _ including Braidwood.
- 2. I have been employed by Commonwealth Edison since 1965 and have held engineering, operating and maintenance positions at various levels of responsibility, including Department Head. Most recently, I have been an Assistant Vice President of Engineering and then the Division Vice President and General Manager of the Fossil Stations Division.
I was made Manager of Projects in 1984 and was elected a Vice President of Commonwealth Edison in 1986.
8608220092 860818 PDR' ADOCK 05000456 PDR G c
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3.. I received'a Bachelor of. Science degree in Electrical--Engineering from the. University.of Illinois in 1962,.and I received a Master'ofLBusiness' Administration-idegreeLfrom Loyola: University in'1972.
- 4. I-am submitting this affidavit ~in support of '
Commonwealth Edison's request for authorization to' load fuel-
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in-Braidwood Unit 1 and to conduct-precritical. testing-of the unit. The precritical. test sequence consists of about 30 individual' test procedures which will verify the satis-factory operation ofJvarious plant systems. During-this r
, - test sequence,:the. plant will be taken from the cold shutdown 4 condition to'no-load operating pressure and temperature.
All'of these various plant systems-will satisfy the operability I ~
requirements defined in the Braidwood Unit 1. Technical Specifications prior to bringing the reactor critical, i 5. -The affidavit of Kenneth D. Brienzo describes several special-measures that Commonwealth Edison will 4 implement throughout:the course of-the fuel loading and precritical testing activities.for which we are seeking i authorization. In particula , he explains that the boron l-E concentration in the reactor coolant system and the makeup water system will be maintained at 2000 parts per million (ppm). .
He also explains that these systems will be manually sampled and tested to verify this boron concentration.
t j Finally, he explains that nonborated water sources will 4
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- be mechanically isolated from the reactor coolant system to preclude inadvertent dilution'of.the boron concentration. I hereby commit, on behalf of Commonwealth Edison Company, that the special measures described in Mr. Brienzo's affidavit will be implemented.
Further affiant sayeth'not.
AM Thomas J. Ma SUBSCRIBED AND SWORN-TO before me this - /7 day of August, 1986.
- smese es
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4 ATTACHMENT C
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) *
) -
COMMONWEALTH EDISON COMPANY ) Docket .o s . 50-456
) 50-457 (Braidwood Station, Units )
1 and 2) )
AFFIDAVIT OF RICHARD J. SLEMBER I, Richard J. Slember, being duly sworn, depose and state:
. 1. I am General Manager of the Nuclear Fuel Divi-sions Business Unit of Westinghouse. I have been responsible for nuclear fuel and reactor safety and engineering activities for over thirty years. I joined Westinghouse in 1955 at the Bettis Atomic Power Laboratory where I was responsible for designing reactor cores for the nuclear navy. From 1963 to 1971, at United Nuclear Corporation, I managed the design of reload nuclear fuel for various nuclear systems, including those supplied by Westinghouse. From 1971 to the present, I have managed a succession of technical activities for ,
Westinghouse, encompassing nuclear fuel design, testing and fabrication; reactor safety analysis and testing; and plant systems engineering.
- 2. I am a 1955 graduate of Cooper Union with a BME degree. I later earned M.S. and Ph.D. degrees in Mechanical Engineering from the University of Pittsburgh. I have taught i
i
courses in the-Bettis Laboratory Reactor Engineering School, and graduate programs at.the Carnegie Institute of Technology and the Polytechnic Institute of Brooklyn.
l
- 3. I am submitting this affidavit in support of i
Commonwealth Edison Company's Motion for Authorization of Fuel Loading and Precritical Testing. As explained in the affi-davits of Thomas J. Maiman and Kenneth D. Brienzo, Commonwealth 1
Edison will operate Braidwood Unit 1 under the authority being requested in a manner such that the concentration of boron within the reactor vessel will be maintained at or above 2000 parts per million (ppm) throughout the fuel loading process and precritical testing sequence without relying on the proper functioning of any electrical systems or circuitry. The purpose of my affidavit is to show that if this concentration of boron is maintained there will be no physical means of the reactor core becoming critical, and therefore no electrical systems or circuitry will be required under accident and transient conditions.
- 4. The reactor core becomes critical when the number of neutrons generated in the core is in equilibrium with the number of neutrons absorbed or lost. The reactor remains ,
subcritical when more neutrons are absorbed or lost than generated. Neutrons that are lost cannot thereafter affect criticality. There are two forms of neutron absorbers--
control rods and dissolved boron in the reactor coolant. The effect of the neutron absorbers is influenced by changes in the
reactor coolant system temperature. Standard design calcula-tions taking into account these temperature effects have demonstrated that with all control rods withdrawn from the core, the boron concentration would have to be reduced to lenc than 1200 ppm for the core to become critical over the range of reactor coolant system temperatures which will occur during the precritical testing sequence. These standard criticality calculations are part of the core design for Braidwood and were performed by nuclear core design engineers within my area of responsibility.
- 5. For the core to become critical, the excess neutron absorbers would have to be removed. This can only be done by withdrawing control rods and/or reducing the boron concentration. Given the Commonwealth Edison commitment to maintain the concentration of boron in the reactor coolant system at or above 2000 ppm, substantially above the 1200 ppm shown necessary by the Westinghouse calculations, the with-drawal of all of the control rods cannot cause the reactor to become critical. Only dilution of the boron concentration in the reactor coolant could cause the reactor to become critical. Such dilution will be precluded by the measures ,
discussed in the affidavit of Kenneth D. Brienzo.
- 6. The generation of neutrons is dependent upon the presence of reactor coolant (water). If reactor coolant is lost from the core, both the neutron generation capability of the fuel and the neutron absorption capability of the boron I
-p 6
dissolved in the water will be reduced. Evaluations performed by Westinghouse under my area of responsibility show that the effect on neutron generation dominates the effect on neutron absorption, making the core even more subcritical. In addi-tion, a loss of heat removal capability from the core is unimportant under the limited operation contemplated by Commonwealth Edison because the reactor core will never become critical and is therefore not a heat source.
- 7. In conclasion, under the conditions that Commonwealth Edison will maintain, Braidwood Unit 1 will remain in a subcritical state under accident and transient conditions without any reliance on electrical systems or circuitry.
l Maintaining the boron concentration in the reactor coolant system at or above-2000 ppm alone will assure the suberitical
. state of the reactor. It follows, of course, that because the reactor will never become critical during either the fuel loading process or precritical testing, no fission product l source term will be generated; and consequently, no question will arise as to the protection of the public health and safety.
Further affiant sayeth not.
4 f
Richard J. Slember l SUBSCRIBED AND SWORN to before me this day l of , 1986.
l l
NOTARY PUBLIC
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1
,9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In tho Matter oft )
COMMONWEALTH EDISON COMPANY )
) Docket-Nos. 50-456
) 50-457 (Braidwood Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I, Peter Thornton, one of the attorneys for Commonwealth Edison Company, certify that copies of Applicant's Motion for Authorization of Fuel Loading and Precritical Testing and the attached affidavits of Messrs. Brienzo, Maiman and Slember have been served in the above-captioned matter on all persons listed on the attached Service List by
, Federal Express overnight delivery this 18th day of August, 1986 except where service has been made as otherwise noted.
4 *
, Peter Thornton ISHAM, LINCOLN & BEALE Suite 5000 Three First National Plaza Chicago, Illinois 60602 (312)558-7500 Dated: August 18, 1986
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SERVICE LIST-
.g .a 1
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' Herbert _Grobsman, Esq Mr. William L. Clements schairma,n Chief, Docketing and Services Administrative Law Judge- United States. Nuclear Regulatory Atonic Safety and Licensing Commission Board Office of the Secretary L United States Nuclear Regulatory Washington, DC 20555 Commission
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WashlagLon, DC 20555 *Ms. Bridget Little Rorem 117 North Linden Street Dr. Richard F. Cole .P.O. Box 208 Administrative Law Judge Essex, IL 60935 Atomic Safety and Licensing Board United States Nuclear Regulatory Commission- Douglass W. Cassel, Jr.
Washington, DC 20555 Timothy W. Wright III BPI Dr. A. Dixon Callihan 109 North Dearborn Street Administrative Law Judge Suite 1300 1911 Parkview Street Chicago, IL 60602 Huntington, West Virginia 25701 Charles Jones, Director Stuart Treby, Esq. Illinois Emergency Services Elaine I. Chan, Esq. and Disaster Agency Office of the Executive Legal 110 East Adams Director Springfield, IL 62705 United States Nuclear Regulatory Commission William Little, Director Washington, DC 20555 Braidwood Project Region III Atomic Safety and Licensing United States Nuclear Regulatory Board Panel Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555 Ms. Janice A. Stevens
' Atomic Safety and Licensing United States Nuclear Regulatory Appeal Board Panel Commission United States Nuclear Regulatory 7920 Norfolk Avenue Commission Phillips Building Washington, DC 20555 Bethesda, MD 20014 (For ADDRESSEE ONLY)
- Robert Guild 314 Pall Mall-Columbia, So. Carolina 29201 George L. Edgar, Esq.
Thomas A. Schmutz, Esq.
- Service by United States Newman & Holtzinger, P.C.,
mail, postage prepaid. 1615 "L" Street, N.W.
Suite 1000
_ - . - _ . .