ML20074A780
| ML20074A780 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/11/1983 |
| From: | George Minor NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | |
| References | |
| NUDOCS 8305160068 | |
| Download: ML20074A780 (13) | |
Text
..
~
e t
c A
UNITEt STATES OF AMERIC,
D NUCLEAR REGULATORY COMMI ONff BEFORE THE ATOMIC SAFETY AND LIP 54SI43G [01
)
G%$R;g7 In the Matter of
)
I
)
"C PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443 NEW HAMPSHIRE, et al.
)
50-444
)
(Seabrook Station, Units 1
)
and 2)
)
)
AFFIDAVIT OF GREGORY C. MINOR REGARDING ENVIRONMENTAL QUALIFICATION OF ELECTRIC VALVE OPERATORS CS-HCV-189, CS-HCV-190, AND RC-V81 Gregory C. Minor, being duly sworn, deposes and says:
1.
I am a consulting engineer with MHB Technical Associates in San Jose, California.
2.
I have worked for over 20 years in the nuclear. industry in a variety of positions including the design, manufacturing, construction, maintenance and analysis of nuclear plants, systems and components.
A list of my professional qualifications is attached to this affidavit.
3.
I have reviewed the NRC Staf f's affidavit of April 20, 1983, concerning qualification of electric valve operators at the Seabrook nuclear power plant.
4.
Unqualified valve operators CS-HCV-189 / CS-HCV-190, and RC-V81 (items 13 and 14 of the Staff affidavit) are located in series on the same letdown line.
Safety grade containment 8305160068 830511 PDR ADOCK 05000443 o
4 2
isolation valve CS-V149 is also located on this line.
See FSAR Figure 9.3-13.
5.
The NRC Staff states that the systems associated with electric valve operators CS-HCV-189, CS-HCV-190, and RC-V81 are not relied upon during post-accident operations.
NRC Staff Affidavit at 5.
Those electric valve operators, however, could be relied upon if feed and bleed were used as a means of cooling the reactor during an accident.
Under those circumstances, the containment isolation valve, CS-V149 could not be relied upon because it is capable only of stopping, not controlling, coolant flow.
Instead, electric valve operators CS-HCV-189, CS-HCV-190, and RC-V81 would be called upon to control the " bleeding" of hot reactor coolant from the letdown line.
6.
The Westinghouse Owners Group Emergency Response Guidelines are being used as the basis for the development of the Seabrook Station Emergency Operating Procedures.
Letter from J. DeVincentis, Yankee Atomic Electric Co., to D.G.
Eisenhut, NRC, dated April 14, 1983.
Enclosure at 3.
Those emergency response guidelines rely on the feed and bleed mechanism for reactor cooling following safety injection.
They also rely on balancing of charging and letdown flows to equilibriate primary and secondarysteam generator pressures during steam generator tube rupture accidents.
6.
Since feed and bleed may be relied on at Seabrook for
3 cooling the reactor following certain accident conditions, the failure of electric valve operators CS-HCV-189, CS-HCV-190, and RC-V81 could prevent desired modes of cooling and thereby l
impact the functioning of safety related equipment.
Therefore these electric valve operators must be considered important to safety under the definition of 10 C.F.R. S 50.49(b)(2), and must be environmentally qualified pursuant to 10 C.F.R.
S 50.49(a).
GREGORY C. MINOR l
l Subscribed and sworn to before me this //" day of h my l
1983.
YQSn.
NOTARY PUBLIC My Commission expires gr-/5e/f/.
l
4 STATEMENT OF MATERIAL FACTS REGARDING ELECTRIC VALVE OPERATORS SA-SV-4A/B AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD 1.
In its evaluation of valve operators SA-SV-4A/B, the Staff states both that "there are no components that require air to perform their safety function" and that "all safety related air operated valves will fail in the safe position."
This implies a contradiction because the air supply does serve safety related valves.
Failure of the air supply (in a high or low condition) could provide an excessive pressure on the safety related valve operators and related equipment or a misleading indication of valve status to the operator.
(
9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
i
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443 NEW HAMPSHIRE, et al.
)
50-444
)
(Seabrook Station, Units 1
)
and 2)
)
)
AFFIDAVIT OF GREGORY C. MINOR REGARDING ENVIRONMENTAL QUALIFICATION.
OF ELECTRIC VALVE OPERATORS SA-SV-4A/4B i
Gregory C. Minor, being duly sworn, deposes and says:
1.
I am a consulting engineer with MHB Technical Associates in San Jose, California.
2.
I have worked for over 20 years in the nuclear industry i
in a variety of positions including the design, manufacturing, construction, maintenance and analysis of nuclear plants, f
systems and components.
A list of my professional qualifications is attached to this affidavit.
i 3.
I have reviewed the NRC Staff affidavit concerning l
l environmental qualification of electric valve operators at l
l Seabrook.
4.
In its evaluation of valve operators SA-SV-4A/B, the Staff states both that "there are no components that require l
air to perf orm their safety function" and that "all safety i
related air operated valves will fail in the safe position."
l t
I
O:
2 This implies a contradiction because the air supply does serve safety related valves.
Failure of the air supply (in a high or low condition) could provide an excessive pressure on the valve operator and related equipment or a misleading indication of valve status to the operator.
These conditions do not appear to be fully evaluated by the Staff (NRC Staff Affidavit 9 p.
5).
The Staff affidavit does not support a finding that containment service air system electric valve operators l
SA-SV-4A/4B are not important to safety.
Gregory C.
Minor Subscribed and sworn to before me this //" day of N4f 1983.
Q hi$c.de.sr NOTARY PUBLIC l
MyCommissionexpiresF/W/F/.
i l
w-a
,em--
- m e
,,,,w.-
,w,
PROFESSIONAL QUALIFICATIONS OF GREGORY C.
MINOR f
GREGORY C.
MINOR MHB Technical Associates j
1723 Hamilton Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPE RIEN CE :
1976 - PRESENT Vice-President - MH B Technical Associates. San Jose, California.
Engineering and energy consultant to state, federal, and private organizations and individusals.
Major activities include studies of safety and risk involved in energy generation, providing tech-nical consulting to legislative, regulatory.public and private groups and expert witness in behalf of state organizations and citizens' groups.
Was co-editor of a critique of the Reactor Safety S tudy (WASH-1400) for the Union of Concerned Scientis ts and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission.
Served on the Peer Review Group of the NRC/TMI Special Inquiry Group (Rogovin Committee).
Actively involved in the Nuclear Power Plant standards Committee work for i
the Instrument Society of America (ISA).
1972 - 1976 Manager, Advanced Control and Instrumentation Engineering, General Electric Company, Nuclear Energy Division, S an.To se,
i Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the measurement, control and operation of nuclear reactors.
Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic.
Responsi-bilities included coordinating and managing the design and j
development of control systems, safety systems, and new control' I
concepts for use on the next generation of reactors.
The position included responsibility for standards applicable to control and instrumentation, as well as the design of short-term solutions to field problems.
The disciplines involved included electrical and mechanical engineering, seismic design and process computer control /
programming.
l l
i
1970 - 1972 i
Manaaer. Reactor Control Systems Desian. General Electric Company, j
Nuclear Eneray Division. San Jose. California.
i Managed a group of seven engineers and two support personnel in i
j the design and preparation of the detailed system drawings and control documents relating to safety and emergency systems j
for nuclear reactors.
Responsibility required coordination with other design organizations and interaction with the customer's engineering personnel, as well as regulatory personnal.
1963 - 1970 l
Desian Engineer, General Electric Company. Nucle.sr Eneray Division, San Jose. California.
t Responsible for the design of specific. control and instrumentation systems for nuclear reactors.. Lead design. responsibility for various i
subsystems of instrumentation used to measure neutron flux in the reactor during startup and intermediate power operation.
Performed lead system design function in the design of a major system for l
measuring the power generated in nuclear reactors.
Other responsi-I bilities included on-site checkout and testing of a complete reactor i
control
- system at an experimental reactor in the Southwest.
Received patent for Nuclear Power Monitoring System.
1960 - 1963 Advanced Engineering Program, General Electric Company; Assignments in Washington. California, and Arizona, t
Rotating assignments in a variety of disciplines:
Engineer, reactor maintenance and instrument design, KE and D reacto rs, Han f ord, Washing ton, circuit design 3
and equipment maintenance coordination.
Design engineer, Microwave Department, Palo Alto, Cali-fornia.
Worked on design of cavity couplers fo r TWT's.
l Design engineer, Computer Department, Phoenix, Arizona.
t Design of core driving circuitry.
- Design engineer, Atomic Power Equipment Department, San Jose, California.
Circuit design and analysis.
Design engineer, Space Sys tems Department, Santa Barbara, j
Prepared control portion of satellite proposal.
1 4 1 1
-,_-.m.
___,._m_.
o
- Technical Staff - Technical Military Planning Operation.
(TEMPO), S an ta B arb ara, California.
Prepare analysis of missile exchanges.
During this period, completed three-year General Electric program of extensive education in advanced engineering principles of high-er mathematics, probability and analysis.
Also completed courses in Kepner-Tregoe, Ef f ective Pres entation, Management Training Pro-gram, and various technical seminars.
EDUCATION University of California at Berkeley, BSEE, 1960'.
Advanced Course in Engineering - three-year curriculum, General Electric Company, 1963.
S tanf ord University, MSEE, 1966.
HONO RS AND ASSOCI ATIONS
- Tau Beta Pi Engineering Honorary Society.
- Co-holder of U.S.
Patent No. 3,565-760, " Nuclear Reactor Power Monitoring Sys tem," February, 1971.
- Member:
American Association for Advance of Science.
- Member:
Nuclear Power Plant Standards Committee, Ir tru-ment Society of America.
PERSONAL DATA Born:
June 7, 1937 Married, three children Residence:
S an Jos e, California
(
l _ _ _
. ~_
P UBLI CATIONS AND TESTIMONY 1.
G. C. Min o r, S.E. Moore, " Control Rod Signal Multiplexing,"
IEEE Transactions on Nuclear Science, Vol. NS-19, February, 1972.
2.
G.C. Minor, W.G. Milam, "An Integrated Control Room Sys tem for a Nuclear Power Plant," NEDO-10658, presented at In-ternational Nuclear Indus tries Fair and Technical Meetings, October, 1972, Basle, Switzerland.
3.
The above article was also published in the German Technical Magazine, NT, March, 1973.
4.
Testimony of G.C. Minor, D.G. B ridenbaugh, and:R.B. Hubbard before the Joint Committee on Atomic Energy, Hearings held February 18, 1976, and published by the Union of Concerned S cientis ts, Cambridge, Massachusetts.
5.
Testimony of G.C. Minor, D.G. B ridenbaugh, and R.B. Hubbard before the California S tate Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.
f' 6.
Testimony of G.C. Minor and R.B. Hubbard before the Cali-i
.fornia S tate Senate Committee on Public Utilities, Transit, j
and Energy, March 23, 1976.
7.
Testimony of G.C. Minor regarding the Grafenrheinfeld Nu-clear Plant, March 16-17, 19 77, Wurzburg, Germany.
8.
Testimony of G.C. Minor before the Cluf f Lake Board of In-quiry, Regina, Saskatchewan, Canada, September 21, 1977.
9.
The Risks of Nuclear Power Reactors:
A Review of the NRC Reactor S af ety S tudy WASH -1400 (NUREG-75/0140), H. Kendall, 4
et al, edited by G.C. Minor and R.B. Hubbard for the Union of Concerned S cientis ts, August, 1977, 10.
Swedish Reac tor S af ety Study:
B ars eb*dek Risk Assessmen t, MHB Technical Associates, January, 1978.
(Published by Swedish Department of Industry as Document S d1 19 78 :1) 11.
Testimony by G.C. Minor before the Wisconsin Public Service Co mmis s ion, February 13, 19 78, Loss of Coolant Accidents:
Their Probability and Consequence.
12.
Testimony by G.C.
Minor before the California Legislature Assembly Committee on Resources, Land Use, and Energy, AB 3108, April 26, 1978, Sacramento, California. I
?
PUBLICATIONS AND TEST! MONY
- 13. Presentation by G.C.
Minor before the Federal Minis try for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man / Machine Interface in Nuclear Reactors, August 21,'and September 1, 1978, Bonn, Germany.
- 14. Testimony by G.C. Minor, D.G.
Bridenbaugh, and R.B. Hubbard, before the Atomic Safety and Licensing Board, September 25,
.1978, in the matter of the Black Fox Nuclear Power S tation Construction Permit Hearinge, Tulsa, Oklahoma.
- 15. Testimony of G.C.
Minor, ASL3 Hearings Related to TMI-2 Accident, Rancho Seco Power Plant, on behalf of Friends of the Earth, September 13, 1979.
- 16. Testimony of G.C. Minor before the Michigan State Legisla-ture, Special Joint Committee on Nuclear Energy, Implications of Three Mile, Island Accident for Nuclear Power Plants in Michigan, 10/15/79
- 17. A Critical View of Reactor Safety, by G.C.
Minor, paper presented to the American Associatidn for the Advancement of Science, Symposium on Nuclear Reactor Saf ety, January 7, 1980, San Francisco, California.
- 18. The Effects of Aging on Safety of Nuclear Power Plants, paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1, 1980.
- 19. Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, S ep temb er, 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.
- 20. Testimony of G.C. Minor and D.G.
Bridenbaugh before the New York S tate Public Service Commission, Shoreham Nuclear l
Plant Construction Schedule, in the matter of Long Island Lighting Company Temporary Rate Case, September 22, 1980.
- 21. Testimony of G.C.
Minor and D.G. Bridenbaugh before the New Jersey Board of Public Utilities, Oyster Creek 1980 Refueling Outage Investigation, in the matter of Jersey Central Power and. Light Rate Case, February 19, 1981.
l.
CERTIFICATE OF SERVICE I certify that on May 12, 1983, NECNP MOTION TO FILE OUT OF TIME ANSWER TO NRC STAFF AFFIDAVIT REGARDING ENVIRONMENTAL QUALIFICIATION OF ELECTRIC VALVE OPERATORS and NECNP ANSWER TO NRC STAFF AFFIDAVIT REGARDING ENVIRONMENTAL QUALIFICATION OF ELECTRIC VALVE OPERATORS were served by first-class mail or as otherwise indicated on the following:
- Helen Hoyt, Esq., Chairperson Rep. Roberta C. Pevear Atomic Saftey and Licensing Board Drinkwater Road Panel Hampton Falls, NH 03844 U.S. Nuclear Regulatory Commission Washington, DC 20555
- Dr. Emmeth A. Luebke Phillip Ahrens, Esq.
Administrative Judge Assistant Attorney General Atomic Saftey and Licensing Board State House, Station #6 U.S. Nuclear Regulatory Commission Augusta, ME 04333 Washington, DC 20555
- Dr. Jerry Harbour Robert A. Backus, Esq.
Administrative Judge 111 Lowell Street Atomic Saftey and Licensing Board Manchester, NH 03105 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board
- Thomas G. Dignan, Esq.
Panel R. K. Gad, III, Esq.
U.S. Nuclear Regulatory Commission Ropes and Gray Washington, DC 20555 225 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Appeal Dr. Mauray Tye, President l
Board Panel Sun Valley Asociation l
U.S. Nuclear Regulatory Commission 209 Summer Street Washington, DC 20555 Haverhill, MA 01830 Docketing and Service Roy P. Lessy, Jr. Esq.
U.S. Nuclear Regulatory Commission Robert G. Perlis, Esq.
Washington, DC 20555 Office of the Executive -
Legal Director Maynard B. Pearson U.S. Nuclear Regulatory Director of Civil Defense Commission i
Town Hall Washington, DC 20555 Amesbury, MA 01913 Mr.'Angie Machiros Anne Verge, Chair Chairman Board of Selectman Board of Selectmen Town Hall Town of Newbury South Hampton, NH 03842 Newbury, MA 09150
Jo Ann Shotwell, Esq.
George Dana Bisbee, Esq.
Assistant Attorney General Edward L.. Cross, Jr., E69 Department of the Attorney Asst. Atty. Generals General State House Annex 1 Ashburton Place,19th Floor Concord, NH 03301 Boston, MA 02108 John B. Tanzer Letty Hett, Selectman Town of Hampton Town of Brentwood 5 Morningside Drive RFD Dalton Road Hampton, NH 03842 Brentwood, NH 03833 Edward F. Meany Sandra Gavutis Town of Rye Town of Kensington 155 Washington Road RFD 1 Rye, NH 03870 East Kensington, NH 03827
- Ruthanne G. Miller, Esq.
Diana P. Sidebotham Law Clerk to the Board R.F.D.2 Atomic Safety and Licensing Board Putney, VT 05346 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard E. Sullivan, Mayer City Hall Newburyport, MA 01950 Alfred V. Sargent, Chairman Donald E. Chick Board of Selectmen Town Manager Town of Salisbury, MA.
01950 10 Front Street Exeter, NH.
03833 Diana P. Randall 70 Collins Street Seabrook, NH.
03874 1- -
Diane Curran 1
Hand Delivery
- Express Mail
-.