|
---|
Category:AFFIDAVITS
MONTHYEARML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20057B0261993-08-0909 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20057B0271993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Re Maint & Surveillance Activities at Plant ML20057B0301993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance of Activities at Plant ML20057B0181993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from Rept Prepared by INPO Re Maint & Surveillance Activities at Plant ML20057B0221993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20045G9811993-06-30030 June 1993 Affidavit.* INPO Rept Should Not Be Disclosed Because San Luis Obispo Mothers for Peace Need for Document Do Not Outweigh Interests of Pg&E,Inpo & NRC & Public in Disclosure.W/Certificate of Svc ML20045G9901993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Supplemental Response to Second Set of Interrogatories & Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20045G9821993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Third Set of Supplemental Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace ML20045A7041993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Miscellaneous Requests for Production of Documents ML20045A7031993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) ML20036A6691993-05-0707 May 1993 Affidavit.* Affidavit of Ja Lee Re Question Two in 930416, ASLB Memorandum, Asking What Rationale Explains Apparent Inconsistency Between NRC Staff Evaluation of Thermo-Lag as Combustible in NRC in 92-82.W/Certificate of Svc ML20036A4381993-04-21021 April 1993 Affidavit of Am Dummer in Support of NRC Staff Response to San Luis Obispo Mothers for Peace Motion for Leave to File Addl Discovery Re Okonite Cables W/Bonded Jackets.* W/ Certificate of Svc ML20035G3311993-04-21021 April 1993 Affidavit of Am Dummer in Support of NRC Staff Response to San Luis Obispo Mothers for Peace Motion for Leave to File Addl Discovery Re Okonite Cables W/Bonded Jackets.* W/Certificate of Svc ML20045G9931993-04-13013 April 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Second Set of Interragotories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20035B6031993-03-12012 March 1993 Affidavit.* Affidavit of Bw Giffin Re Info Answering to Interrogatories C-6,C-8,C-9,C-10,C-11,C-12,C-13,C-14,C-15, C-16,C-17,C-19,C-21 & Document Requests E-7,E-10,E-11,E-16, E-17,E-18,E-20,E-21,E-22,E-24 & E-26 Included in Util Encl ML20035B6161993-03-12012 March 1993 Affidavit.* Affidavit of Rc Anderson Re Info Answering to Interrogatories C-1,C-2,C-3,C-4,C-5,C-24 & Document Requests E-3,E-4,E-5,E-6,E-13,E-14 & E-15 Included in Attached Util Response ML20035B5861993-03-10010 March 1993 Affidavit.* Affidavit of Dk Cosgrove Re Info Answering Interrogatories B-1b,B-1c,B-2,B-3,B-4,B-5,B-9,B-10,B-11, B-12,B-13 & Document Requests D-4,D-5,D-8,D-9,D-10,D-20, D-26,D-28 & D-29 Included in Attached Util Response ML20035B6151993-03-10010 March 1993 Affidavit.* Affidavit of Pl Prudhon Re Info Answering to Interrogatories C-12 & Document Requests E-20 & E-24 Included in Attached Util Response ML20035B5931993-03-10010 March 1993 Affidavit.* Affidavit of AL Nicholson Re Info Answering to Interrogatories B-18,B-19 & Document Requests D-24 Included in Attached Util Response ML20035B6091993-03-10010 March 1993 Affidavit.* Affidavit of Ja Davis Re Info Answering Interrogatories C-12,C-19 & Document Requests E-20,E-22 & E-24 Included in Attached Util Response ML20035B6191993-03-10010 March 1993 Affidavit.* Affidavit of Dr Clifton Re Info Answering to Interrogatories C-18,C-20 & Document Requests E-19 & E-23 Included in Attached Util Response ML20128B8341992-11-30030 November 1992 Affidavit of as Masciantonio in Support of NRC Staff Response to Mothers for Peace Suppl to Petition to Intervene.* W/Certificate of Svc ML20116F0631992-10-0707 October 1992 Affidavit of R Becker.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20116F0551992-10-0606 October 1992 Affidavit of E Holder.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20116F0701992-10-0606 October 1992 Affidavit of Biesek.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed. Encl ML20116F0361992-10-0606 October 1992 Affidavit of N Culver.* Affidavit Re Safety Concerns of Plant Operation During CP Recapture ML20235S0091987-10-0202 October 1987 Affidavit of Jd Shiffer.* Explains Util Planned Expansion of Facility Spent Fuel Storage Capacity & Why Delay in Reracking Schedule,Such as Would Be Occassioned by Stay,Will Cause Substantial Harm to Util.Certificate of Svc List Encl ML20216J8641987-06-29029 June 1987 Declaration of Ef Lowry.* Tm Novak Board Notification 87-05 Re Draft BNL Rept Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Received in Late Mar or Early Apr 1987.Proof of Svc Encl ML20216J8471987-06-26026 June 1987 Affidavit of SA Silver Informing That Draft BNL Rept, Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Not Received ML20216J8191987-06-25025 June 1987 Affidavit of RB Ferguson Re Notification of Generic Issue 82.* Board Notification 87-05 Re Generic Issue 82 Concerning Beyond design-basis Accidents in Spent Fuel Pools False & Misleading ML20216J8371987-06-25025 June 1987 Affidavit of N Culver Informing That Board Notification 87-05 Re Draft BNL Rept on Spent Fuel Pool Accidents Never Received ML20213A0331987-01-13013 January 1987 Affidavit of Kp Singh Re Mothers for Peace & Sierra Club 861215 Motion for Summary Disposition Concerning Design of high-density Spent Fuel Racks.Racks Designed in Compliance W/Applicable NRC & SRP Requirements.Certificate of Svc Encl ML20205F6271986-08-15015 August 1986 Affidavit of Pw Niles Reporting Results of Calculations Performed on Postulated Hosgri Event Data ML20206J4751986-06-24024 June 1986 Affidavit of Wl Brooks Re Intervenors 860616 Application for Stay & RB Ferguson 860616 Affidavit Re Expansion of Spent Fuel Pools.Certificate of Svc Encl ML20206J4201986-06-24024 June 1986 Affidavit of Rc Herrick on 860624 Re Intervenors 860616 Application for Stay & RB Ferguson Affidavit Re Proposed Reracking of Spent Fuel Storage Sys ML20206D7501986-06-18018 June 1986 Affidavit of Jd Shiffer Re Proposal to Increase Spent Fuel Storage Capacity,Approved by NRC on 860530.Intervenor Risk Allegations Refuted.W/Certificate of Svc ML20199D1271986-06-15015 June 1986 Affidavit of RB Ferguson Concluding That Spent Fuel Reracking at Facilities Presents Significant Safety Hazard to Surrounding Environ & Population & Poses Risk of Irreversible Contamination ML20099H6491985-03-0505 March 1985 Affidavit of a Jackson Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Technical & Safety Significance of Issues Raised in 841115 Affidavit Re Flud Computer Program.Errors in Program May Lead to 100% Inaccurate Predictions ML20099H6261985-03-0404 March 1985 Affidavit of L Kinney Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Charges of Matl False Statements by Util in Response to Allegations Jir 75-78 & 80 ML20099H6061985-02-24024 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Concern Over NRC Response to 841127 Disclosure of Significant Engineering Errors & QA Violations in Design of Pipe Supports ML20099H7281985-02-22022 February 1985 Affidavit of Tj Oneill Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Matl Licensing Issues Resolved by NRC on Basis of False Statements & Omissions.Failure of Diablo Canyon Allegation Mgt Program Described.New Info Encl ML20099H5021985-02-0606 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Deficiencies W/Engineering Practices on Large Bore Piping & Pipe Supports ML20099H5591985-02-0404 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re QA Problems in Drafting Dept,Hardware Deficiencies,Mgt Opposition to Reporting Deficiencies to QA & Failure to Follow Engineering Specs ML20099H5741985-01-23023 January 1985 Affidavit of Ho Hudson Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Deficiencies in Cardinal Industrial Products Qa.Corrective Actions Did Not Address Matls Previously Installed.Supporting Documents Encl ML20099H7751985-01-23023 January 1985 Affidavit of Mc Thompson Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Addl Concerns on Issues Examined in 850108 Interview.Supporting Documentation Encl ML20099H5271985-01-22022 January 1985 Affidavit of P Haffey Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Allegations of Misconducting by Region V & of Util Matl False Statements Concerning Previous Allegations ML20099H6631985-01-21021 January 1985 Affidavit of Jl Mcdermott Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re NRC Mishandling of Previous Allegations.Fifteen New Allegations Listed ML20099H7541985-01-18018 January 1985 Affidavit of CC Stokes Supporting Jl Mcdermott & Tj Oneill 840731 Petition Re Failure of NRC to Honor Rules of Allegation Mgt Program & Matl False Statements by Util in Response to Previous Allegations ML20107C4871984-11-0101 November 1984 Affidavit of Tm Devine Re Employee Concerns That Reactor Vessel Level Instrumentation Sys May Not Provide Reliable Readings 1994-03-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20206F0101999-05-0303 May 1999 Exemption from Requirements of 10CFR50.60 & 10CFR50,App G,Re Pressure Temp Limits & Min Temp Requirements for Plant,Units 1 & 2.Exemption Related to Application & Suppls ,0205 & 0317 to Allow Use of Code Case N-514 ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp DD-99-05, Directors Decision DD-99-05 Responding to 981124 Petition Under 10CFR2.206 Requesting That OLs Be Modified to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture.Intent of Petition Met1999-03-12012 March 1999 Directors Decision DD-99-05 Responding to 981124 Petition Under 10CFR2.206 Requesting That OLs Be Modified to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture.Intent of Petition Met ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20216C7461998-03-12012 March 1998 Exemption from Requirements of 10CFR50.71 Re Submission of Rev to FSAR & Design Change Repts of Facility Changes Made Under 10CFR50.59 for Plant,Units 1 & 2 ML20199C0901997-11-12012 November 1997 Exemption from Requirements of 10CFR70.24 Re, Criticality Accident Requirements ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20092M1811995-09-26026 September 1995 Exemption from Requirements of 10CFR73.55, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage at Plant Units 1 & 2 ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs ML20087H1661995-04-12012 April 1995 Exemption from Schedular Requirement to Conduct Biennial Exercise of Emergency Plans for One Year to Prevent State of CA from Having to Conduct Exercises for Diablo Canyon & San Onofre in Same Year ML20082H9151995-04-11011 April 1995 Exemption from 10CFR50,App J,Section III.D.1.(a),allowing Three Type a Tests to Be Conducted at Approx Equal Intervals W/Third Done During Plant Shutdown for 10-yr ISI DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 1999-09-20
[Table view] |
Text
EXHIBIT.19 UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LTCENSING BOARD In The Matter Of
)
)
PACIFIC GAS & ELECTRIC COMPANY )
)
(Diablo Canyon Nuclear Power
)
Plant - Units 1 & 2)
)
Docket Nos.
50-275 O.L.
50-323 O.L.
AFFIDAVIT 'OF GREGORY 'C.'INOR Concerning ISSUES" RELATED TO VESSEL'EVEL'EA'SURZMENT STATE OF CALIFORNIA
)
)
COUNTY OF SANTA CLARA )
ss.
follows; GREGORY C.
MINOR deposes and says under oath as I'.
BACKGROUND OF AUTHOR 1.
My name is Gregory C. Minor. I have twenty years of experience in the design, development,
- research, start-up, and management of nuclear reactor systems.
I worked for sixteen years for the General Electric Company and for the past four years as an independent technical consultant.
I was a founder in 1976,
~ ~
Fl
and I am now vice president of MHB Technical Associates.
I received a B.S. in electrical engineering from the University of California, Berkeley, and an M.S. in electrical engineering from Stanford University.
My sixteen years with G.E. involved the design, development, and testing of safety and control sys-tems for -nuclear plants.
Since 1976, I have participated in a variety of reactor studies addressing nuclear safety issues.
I
'am presently a consultant on several nuclear plant cases con-cerning.the adequacy of current designs to meet existing regula-tions.
I am a member of the Nuclear Power Plant Standards Com-mittee for the Instrument Society of 'America.
Also, I partici-pated in a Peer Rev'iew'roup of the NRC/TMI Special Inquiry Group investigating the'MI 'acci;dent.
My complete experience record is appended to this affidavit astt'ach'me'nt
'A.
1X'.
PURP'OSE 2.
The purpose of this affidavit is to define the sub-stantive issues related to the proposed vessel level measurement technique for discerning inadequate core cooling at Diablo Canyon,
'II.'NTRODUCTION 3.
The TMI-2 operators'nability to detect low vessel water level was exacerbated by lack of a direct reading water level measurement and thus directly contributed to the accident".,
Diablo Canyon presently has no installed instruments to directly
measure the water level in the reactor pressure vessel.
The lack of direct measurement greatly limits the ability of the operator to unambiguously detect'the approach of low water level in the reactor core.
The NRC's requirements for correc-tion of this deficiency have been expressed in the Lessons Learned Task Force Report (NUREG-0578),
the TMI Action Plan (NUREG-0660),
and also the Requirements for NTOL's (NUREG-0737).
The Applicant's proposed solution is to install a Westinghouse system which is still developmental and has several deficiencies which may prevent it from providing an -unabiguous easy-to-inter-pret indication of low water lev'el and inadequate core, cooling.
The following information describes the technical issues related to the Applicant's proposed system.
IV. 'ISCUSSION OF ISSUES 4.
The presently installed instruments Diablo Canyon operators will rely upon for indications of inadequate core
~
I cooling (ICC) are the same type of instruments relied upon during the TMI-2 accident, but with a wider range of readout; namely:
wide range reactor coolant pressure, wide range reactor coolant temperature and core exit thermocouples.
There is general 1/
agreement that present displays do not provide an indication of vessel water level.
1/
Affidavit of Hoch & Shiffer, at page 2.
5.
By themselves, the coolant pressure and temperature measurements are not an unambiguous and easy-to-interpret indica-tion of ICC.
Considerable analysis and judgement would be needed to determine if ICC conditions existed based on these two para-meters.
6.
The Applicant plans to use the core exit thermocouple 2/
readings as an indication that ICC has already occurred, in which case the core may already be uncovered and fuel damage may, already be occurring.
They would.then use the thermocouples as an indica-tion of the success of their recovery or mitigation processes.
7.
- Thus, the existing devices for ICC indication are inadequate to give the operator warning of pending ICC but are more of a general indication or after-the-fact ICC indication.
8.
To augment these instruments, the Applicant plans to add a Subcooling Margin Meter (SMM) and a Reactor Vessel Level 3/
Instrumentation System (RVLIS).
The subcooling monitor will pro-vide only a gross indication of coolant conditions to warn the operator when there is the possibility of boiling and void for-mation in the primary loop.
This by itself is not an indication of the core being uncovered or the fuel being inadequately cooled.
2/
Affidavit.of Muench at page 2.
3/
The NRC cites this instrument as existing instrumentation (see SER Supplement 14 at page 3-18), wher'eas, the Applicant cites it as equipment to be added (see Muench at page 2).
9.
- Thus, aside from the RVLIS, there is no instrument present or planned for Diablo Canyon which provides an unambiguous I
indication of the
~a roach to uncovering the core.
10.
The westinghouse system'of vessel level measurement proposed for Diablo Canyon is still under development with ongoing testing not scheduled to be completed until November,
- 1981, and reports to be provided to the NRC by January, 1982.
Despite 4/
its untested and unproven status, the RVLIS is planned for instal-lation in Diablo Canyon before fuel load.
11.
The NRC Staff has conducted only a review of the RVLIS description and concludes it meets the "documentation requirements."
- However, they do not make a finding of acceptability of the total ICC system; postponing that review'o some 'time after January, 1982
/
12.
The RVLIS indication of reactor vessel level does not meet the requirem'ent of being unambiguous and easy to interpret.
There are conditions where the system is described as providing erroneous or uncertain reading of water level. 6/
4/
- Letter, Crane to Miraglia (NRC), re:
additional clarification of PG&E's resolution of NUREG-0737, Item II.F.2, Mar. 19,
- 1981, page 3.
5/
NUREG-0675, SER Supplement 14, April, 1981, page 3-70.
6/
Affidavit of Muench at pages 4 and 5.
13.
The RVLIS system does not provide coverage for all types of transients or accidents and thus might provide ambiguous or misleading information to the operator.
Specifically, readings may be misleading under conditions of void redistribution, level swell, coolant pumps being turned on or off, small breaks in the vessel
- head, and severe accidents such as anticipated transients without scram. (ASS).
14.
During LOCA's of greater than 6-inch break size,,
the Applicant admits that both the RVLXS and the core exit thermo-couples may provide ambiguous indications of ICC.
There is
'/
no assurance that operators will not be, taking manual action during this period.
Also, there is"no way for the operator to know if he is in a period of 'ambiguous, erroneous, or reliable indication from his ICC instruments.
15.
The RVLIS design may have the same single-failure problem as the SMM which relies on a single data processor fed by redundant, inputs and feeding to redundant readout devices.
However, withholding of "proprietary" information makes the Applicant's description of the RVLIS unclear as to the number of data processors and the algorithm used to create the displays.
If there is only one data processor, it is vulnerable to single failure and/or causing erroneous indications on each of the 7/ Ibid 6 at page 4.
redundant displays.
If there 'are two process'ors, there -is no indication of how the operator is to deal with a discrepancy in
'the two output displays.
This is an ambiguous condition which could easily mislead'r confuse the operator.
The system has two additional points of potential single-failure at the vessel penetration points used for sensing pressures for the differential pressure instruments;-
Plugging or blockage of these points could provide an ambiguous and erroneous indication.
16.
The RVLIS data processor(s) and the displays are not req'uired to be qualified for seismic conditions which the plant may be expected to experience:
Thus, there is no assurance that the system will survive a severe earthquake.
In the. event the data processor fails or one of the'edundant displays fails, there appears to be no failure indication or indication as to which of
. 8/
the redundant display devices'he operator is to rel'y upon.'
The result is an ambiguous and/or misleading indication at a time when the opexator may need to rely on the RVLIS.
17.
I disagree with the'Staff's position that vessel water level indication is not needed for reactor operation at low power.
There is no other instrument that the operator can 8/
The NUREG-0737 requirements for Item II.F.2 exempt the data processing device and displays from the full qualifi-.
cation requirements applicable to pose-accident monitoring equipment.
This is not consistent with the need to provide a rel'iable and unambiguous indication for the operator in post-accident conditions.
rely upon for indicating an ap'proach toICC'. 'ne cannot rule out the possibility of accidents, even at low power, which will require swift and accurate operator responses.
The Staff's judgement is that there will be time for the operator to make the necessary diagnoses for mitigation of an accident.
Con-9/
sidering the fact that some safety systems will be disabled for the low po~er tests and the plant is in the shake-down
- phase, 10/
the RVLIS should be available for the operators'se.
- Further, if the low power test phase is to be used by the Applicant as additional training for their operators, they should have the RVLIS available to experience its capabilities and deficiencies before full power operation.
V.
CONCLUSION 18.
Vessel water leve1'easurement is one of the best indicators of the approach of ICC conditions and is therefore a necessary addition to Diablo Canyon.
- However, the pxoposed I
design for Diablo Canyon RVLIS is still unproven and appeaxs to have serious deficiencies in its design and its ability to provide unambiguous, easy-to-interpret indications of ICC over 9/
Affidavit of Phillips at page '7.
'10/ Affidavit of Goesnex at page 2.
the full range of operating and accident conditions.
A vessel level device of proven capability should be added to Diablo Canyon before the plant operates.
,Further the deponent sayeth not.
April 22, 1981 Gr gory C. Minor Subscribed and sworn to before me this
<<',P~ /
day of / Icf>, 1981.
C~
NOTARY PUBLIC My commission expires:
.f~- > 7 -FF J ~~
OFFICIAL SEAL LINDA L ROBERSON NOTARY PU8LIC - CAuFORNIA SANTA CLARA CO'JIITY My comm. expires AUG 29, 1983
1
~
3 ATTACHMENT A PROFESSIONAL UALIFICATIONS OF GREGORY C.
MINOR
~
~
v
~
GREGORY C.
MINOR MHB Technical Associates 1723 Hamilton Avenue Suite K
San Jose, California 95125 (408) 266-2716 E XP E RIEN CE:
19 76 P RESENT l
Vice-President MHB Technical Associates S an Jose, California.
Engineering and energy consultant to state,
- federal, and private oiganizations and individusals.
Major activities include s tudies 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 'roups.
Was co-'editor of a critique of the Reactor Safety Study (WASH-1400) for the Union of Concerned Scientists 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 s tandards Committee work for the Instrument Society of America (ISA).
1972 l976 Mana er Advanced Control and Instrumentation En ineerin General Electric Com an Nuclear Ener Division San Jose, California.
Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the measurement,'ontrol and operation of'ucIedr reactors.
Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission, and custom'ers, both ov'erseas and domestic.
- Responsi, bilities included coordinating and managing the'esign and development of'on'trol'ystems, safety
- systems, and new control 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'hort-term solutions to field problems.
The disciplines involved included electrical and mechanical engineering, seismic design and process computer control/
programming.
1970 1972
~
~
~
~
~
Mana er Reactor Control' s tems Desi n
General Electric Com an Nuclear Ener Division S an Jos'e Cal'ifo'rnia.
Managed a group of seven engineers and two support personnel in the design and preparation'f the detailed system drawings and control documents relating to saf ety and emergency systems for nuclear reactors.
Responsibility required coordination with other design organizations and interaction with the cus tomer's engineering personnel,
-as well as regulatory personnel.
1963 1970 I
Desi n En ineer General Electric Com an Nuclear Ener
- Division, San Jose" California.
Responsible for the design of specific control and instrumentation systems for nuclear reactors.
Lead design responsibility for various 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 measuring the power generated in nuclear reactors.
Other responsi-bilities included on-site checkout and testing of a complete reactor 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 Washin toh California and Arizona.
Rotating assignments in a variety of disciplines:
- Engineer, reactoz maintenance and instrument
- design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.
Design engineer, Microwave Department, Palo Alto, Cali-fornia.
Worked on design of cavity couplers for TWT's.
Design engineer, Computer Department,
- Phoenix, Arizona.
Design of core driving 'circuitry.
Design engineer, Atomic Power Equipment Department, San
- Jose, Calf fornia.
Circuit design and analysis.
Design engineer',
Space Sys tems Department, Santa
- Barbara, California.
Prepared contzol portion of satellite proposal.
Technical S taff Technical Milita'ry Planning Operation.
(TEMPO), Santa Barbara, California.
Prepare analysis of mis s ile exchanges During this period, completed three-year General Electric program of extensive education in advanced engineering principles o f high-er mathematics, probability and analysis.
Also completed courses in Kepner-Tregoe, Effecti've Presentation, Management Training Pro-
- gram, and various technical seminars.
EDUCATION University of California at Berkeley,
- BSEE, 1960.
Advanchd Course in Engineering - three-year curriculum, General Electric
- Company, 1963.
Stanford University,
- MSEE, 1966.
HONORS AND AS SO CI ATIONS Tau Beta Pi Engineering Honorary Society.
Co-holder of U.S. Patent No. 3,565-760, "Nuclear Reactor Power Monitoring System,"
- February, 1971.
Member:
American Association for Advance of Science.
Member:
Nuclear Power Plant Standards Committee, Ins tru-ment Society o f America.
PERSONAL DATA B orn:
June 7,
1937
- Married, three children Residence:
an Jose, California
%1
PUBLICATIONS AND TESTIMONY G.C. Minor, 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 System for a Nuclear Power Plant," NED0-10658, presented at In-ternational Nuclea'r Industries Fair and Technical Meetings,
- October, 1972,
- Basle, Switzerland.
3.
4.
The above article was also published in th'e German Technical
- Magazine, NT, March, 1973.
If V
Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Joint Committee on Atomic Energy, Hearings held February 18,
- 1976, and published by the Union of Concerned Scientis ts, Cambridge, Massachusetts 5.
Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976..
6.
Testimony of G.C. Minor and R.B. Hubbard before the Cali-fornia State Senate Committee on Public Utilities, Transit, and Energy, March 23, 1976.
7.
Testimony of G.C. Minor regarding the Grafenrheinfeld Nu-clear. Plant, March 16-3.7, 1977, Wurzburg, Germany.
8.
Testimony 'of G.C. Minor before the Cluff Lake Board of In-quiry, Regina, Saskatchewan,
- Canada, September 21, 1977.
9.
The Risks of Nuclear Power Reactors.:
A Review of the NRC Reactor Safet Stud 'ASH-1400 (NUREG-75/0140),:H. Keridall, et al, edited by G.C. Minor and R.B. Hubbard for the Union of Concerned S cientis ts, Augus t, 1977.
10.
Swedish Reactor Safet Stud:
Blrseback Risk Assessment, MHB Technical Associates,
- January, 1978.
(Published by Swedish Department of Industry as Document Sd?
1978:1)
Testimony by G.C. Minor before the Wisconsin Public Service Commission, February 13,
- 1978, Loss of Coolant Accidents:
Their Probabilit and Conse uence.
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.
PUB LICATIONS AND TESTIMONY
- 13. Presentation by G.C. Minor,before the Federal Miriis tr 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 Station Construction Permit Hearings,
- Tulsa, Oklahoma.
- 15. Thstim'ony of G.C. Minor, ASLB 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, Im lications of Three Mile Island Accident for Nuclear Power Plants in
~Michi an, 10/15/7$
~
17.
A Critical View of Reactor Safet, by G. C. Minor, paper presented to the 'American Association for the Advancement of Science, Symposium on Nuclear Reactor Safety, January 7,
- 1980, San Francisco, California.
I N
18.
The Effects of A in on*Safet of Nuclear Power Plants, paper presented at Forum on Swedish Nuclear Referendum, S tockholm,
- Sweden, March 1, 1980.
- 19. Minnesota Nuclear Plants Gaseous Emissions S tud, MHB Technical Associates, September,
- 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.
- 20. Testimony of G.C. Minor and D.G. Bridenbaugh before the New York State Public Service Commission, Shoreham Nuclear
. 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 Boa'rd of Public Utilities, 0 ster Creek 1980 Refuelin Outa e Investi ation, in the matter of Jersey Central Power and Light Rate
- Case, February 19, 1981.