ML19345D876

Affidavit Evaluating Plant Const & Impact on Changes to safety-related Structures & Components.Prof Qualifications & List of Publications Encl

ML19345D876
Person / Time
Site:	Seabrook
Issue date:	12/02/1980
From:	George Minor MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML19345D875	List: ML19345D874 ML19345D876
References
NUDOCS 8012170682
Download: ML19345D876 (9)

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t , s ATOMIC S A F i. F Y A?;D I. I C E:: S I ?:(- /. P ' i A I + '> J " il In the Matter of )

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PUBLIC S E RVI CE COMPANi 0F ) Docket Nos. 50-443 NEW HAMPSHIRE, et al. ) 50-444

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(Seabrook Station, Units 1 and 2))

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AFFI DAVIT OF G RE GO RY C. MI N O R EVALUATION OF CONTINUED SE AB ROOK NUCLE AR PLANT CONSTRUCTION AND ITS IMPACT ON CHANGES TO S A F_E TY-RE LATE D S T RUCT URE S AND COMPONENTS G RE GO RY C. MINOR, being duly sworn, deposes and says:

1. I an a consulting. engineer with MHB Technical Associates in San Jose, California.

2. I have worked for 20 years in the nuclear industry in a variety of positions including the deisgn, manufacturing, con-struction, maintenance and analysis of nuclear plants, systems and conponents. A list of ny professionni qualifications is attached to this affidavit.

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. 12, and it nunth; after-wards. These data are for the civil structures of Units 1 and 2 and also for safety-related equipment and materials (both NSS and BOP) .

4. In my opinion, these data do not support the conclusions drawn in the Public Service Company of New Hampshire's November 13, 1980 Motion at page 9, for the following reasons:

5. Seabrook Unit 1 and Unit 2 cannot be treated the same because they are at entirely different stages of completion.

6. Unit 2 is essentially at the start of construction and is therefore most amenable to possible modification in the design resulting from revised seismic parameters. Any further construc-tion in the interim would make the modifications to the civil structures that much more difficult or perhaps impossible.

7. Unit 1 data for civil s truc tu res re an insufficient basis for a decision on continuing construction. An 8-10% increase in percent complete for such important structures as c on tainmen t , con-trol building and auxiliary building may have a large impact on the ability to readily upgrade the design of the structures them-selves and the cafety-related eq u ipmen t they contain. However, O

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:ereof. It t possitt< . iar criticsl p h . <; e c' :he constructica are to be completed in the next six months but are not apparent in the Public Service Company of New Hampshire data.

8. The electrical cable tunnels and penetration areas are shown as having a three-fold increase in completion status in the first six-month period. It is quite possible these area. and the equipment thcy contain would be required to be modified as a result of a substantial increase in the seismic acceleration th e plant may be expected to experience.

9. The data do not provide information on mechanical or electrical equipment and supports as part of the estimated com-pletion status. There is a high likelihood that a substantial increase in seismic loads will require rodification of these i

devices and their supports. Their compir r. ion status is an im-portant input to the decision on construction continuation.

10. The Public S a rvice Company of New Hampshire data on safety-related equipment for NSS and BOP indicate- that Unit 2 i

equipment is still at a level of fabrication where it is of marginal value to halt fabrication. For Unit 1 equipment, it is possibly too late to reap any benefit from stopping fabrica-l tion. !fo re d a t a are required on the type of equ ipmen t and its l

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>1 si a: 4  : (a _ ', !) t :4 <1 i a very low level of completion could benefit by a decision to not complete further construction until the seismic parameters are revis d and the design is re-evaluated. Additional d a t a are needeil to support the decision.

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_/ W CRE O RY!C . MINOR i ,g OFFICit 1 SEAL e f '"" A 8 PO3EP. SON e

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Subscribed and sworn to before me this ru/' day of /2 ' . ) 1980

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.- NOTARY P UBL I C My Commission Expires: [!//r 5' '

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s C. MINOR P ROFES SION AL OUALITICATIONS Or GRECORY G RE C O RY t. MINOR

'M R Technical Associates 1723 Har.ilton Avenue Luite K San Jose, California 95125 ~

(408) 266-2716 E XP E RIEN CE :

1976 - P RE S ENT Vice-P re s id en t - MHB Technical Associates, San Jose, California.

Engineering and ener.gy consultant to state, federal, and private organizations and individusals. Major activities in clud e studies of safety and risk involved in energy generation, providing tech-nical consulting to legislative, regulatory, public and private groups and e.; pert witness in behalf of state organizations and citizens' groups. Was co-editor of a critique of the Reactor S af ety S tudy (WASH-1400) for the Union o f Concerned Scien tis ts and co-author of a risk analysis Served of Swedish on the reactors Peer Review for the of Group Swedish Energy Commission. Actively the NRC/TMI Special Inquiry Group (Rogovin Commit tee) .

involved in the Nuclear Power Plan t stcndards Committee York for the Instrument Society of America (ISA).

1972 - 1976 Manager, Advanced Control and Ins trumentation Engineering, General Electric Company, Nuclear Energy Division, San Jose, California.

Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the me a s u r em en t ..

control and operation of nuclear reactors. Involved coordination the Nuclear Regula tory with other reactor design organizations, Responsi-Commission, and customers, both overseas andthe domestic.

design and bilities included coordinating and managing developnent of control systems, safety systems, and new Thecontrol position concepts for use on the next generation of reactors.

included responsibility for standards applicabic 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 /

progra= ming.

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s a 0; e detailsd w"cter denvinen rod control J o c u.m e n t s rc': tin. to ':ety a r. c c:w r ency 1Jten- with e

for nuclear reactors. Responsibility required c o o r d i n a t i o r, other design organizations and interaction with the customer's engineering personnel, as well as regulatory personnel.

1963 - 1970 .

Design Engineer, General Electric Company, Nuclear Energy Division, San Jose, California.

Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lead design re s p on s ib ili ty for various subsystems of instrumentation used to measure neutron fluxPerformed in the reactor during startup and intermediate power operation.

Icad system design function in the design of a majorOther system for responsi-measuring the power generated in nuclear reactors.

bilities included on-site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest. Received patent f or Nuclear Power Monitoring System.

1960 - 1963 Advanced Engineering P ro gram, General Electric Company; Assignments in W ashin gton , California, and Arizona.

Rotating assignments in a variety of disciplines:

- Engineer, reactor maintenance and instrument design, KE and D reactors, H an f ord , Wa shing ton , circuit design and equipment maintenance coordination.

- Design engineer, Microwave Department, Palo Alto, Cali-fornia. Worked on design of cavity couplers f o r TWT's.

- Design engineer, Computer Department, Phoenix, Arizona.

Design of core driving circuitry.

- Design engineer, Atomic Power Equipmen t Department, San Jose, California. Circuit design and analysis.

- Design engineer, Space Systems Department, Santa Barbara, California. Prepared control portion of satellite proposal.

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cchnical 'ti l 1 t a ry "Ianning Operation (TEMPO), Santa barbara, California. Prepare enclysit of

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D u r t n t; this period, completed three-year General Electric program of extensive education in advanced engineerit,, principler of hinh-er mathematics, probability and analysis. Also completed courses in Kepner-Tregoe, Effective Presentation, Management Training Pro-gram, and various technical seminars.

EDUCATION Unive rs it y of California at Berkeley, BSEE, 1960.

Advanced Course in Engineering - three-year curriculum, General Electric Company, 1963.

S tanf ord Univers ity , MSEE, 1966.

HONORS 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," P eb ruary , 1971.

- Member: American Association for Advance of Science.

- Member: Nuclear Power Plant Standards Committee, Instru-ment Society of America, i PERSON AL DATA Born: June 7, 1937 Married, three children Residence: San Jose, California

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. t -Z 1972 G.C  !!!acr, '.G  : .,

.tecratec Lontrol nom. Systen

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for a Nuclear Power Plant," *ED0-10658, presented at in-ternationni Nuclear Industries Fair and Technical Meetings, O c t ob e r , 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. Bridenbaugh, and R.B. Hubbard before tne Joint Committee on Atomic Energy, Hearings held February 18, 1976, and published by the Union of Concerned S cien t is ts , Camb r id g e , Massachusetts.

5. Testimony of G.C.' Minor, D.C . B r idenbaugh , and R.B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

6. Teatimony 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 thc Grafenrheinfeld Nu-clear Plant, March 16-17, 19 7 7, W ur zbu r g , 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 Safety S tudy WASH-1400 (N U RE G -7 5 / 0140 ) , H. Kendall, et al, edited by G.C. Minor and R.B. Hubbard for the Union of Concerned S cientis ts , August, 1977.

Swedish Reac tor S af ety Study: B ars eb*ack Ris k As s e s smen t ,

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MHB Technical Associates, January, 1978. (Published by Swedish Department of Industry as Document SdI 1978:1) i

11. Testimony by G.C. Minor before the Wisconsin Public Service Commission, February 13, 1978, Loss of Coolant Accidents:

Their P rob ab ili t y and Consequence.

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12. Testimony by G.C. Minor before the California Legislature l

Assembly Committee on Resources, Land Use, and Energy, AB

' 3108, /.pril 26, 1978, Sacramento, Califo rnia ,

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. Hubbard, before : : . tonic 'afety

. ar. L ; c ,_ r 4 I n g i.c.r.r d , S e p t e r; b e r 23, 197S, in the matter of the Elack Fox Nuclear Power S ta t ion Construction Permit Hearings, Tulsa, Oklahoma.

15. Testimony of G.C. Minor, ASLB Hearings Related to TMI-2 Accident, Rancho S eco Power Plan t, 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, 1T[l'5'[f9 -

17. A Critical Vicw of' Reactor Safety, by G.C. Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nuclear Reac tor Safety, Jan ua ry 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 Gascous Emissions Study, MHB Technical Associates, September, 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.

20. T e s t imo ny 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.

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In the ::atter of )

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PUBLIC SERVICE CO;1PANY OF ) Docket Nos. 50-443 NEW HAMPSHIRE, et al. ) 50-444

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(Seabrook Station, Units 1 )

and 2) )

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CERTIFICATE OF SERVICE I hereby certify that a copy of the NECNP Reply to Licensee and Applicant Arguments on Its Motion To suspend Cons truction was hand parties:

delivered this 4th day of December 1980 to the fo]1owing l Alan S. Rosenthal, Chairman Dr. John H. Buck Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Frank Wright, Esquire

• Assistant Attorney General Assistant Attorney General Environmental Protection Division Environmental Protection Office of the Attorney General Division State House Annex, Room 208 Office of the Attorney General Concord, New Hampshire 03301

! One Ashburton Place Boston, Massachusetts 02108

• Thomas G. Dignan, Jr., Esquire Ropes & Gray Robert A. Backus, Esquire 225 Franklin Street O'Neill, Backus, Spielman, & Little Boston, Massachusetts 02210 116 Lowell Street Manchester, New Hampshirc 03101 Docketing and Service Section U.S. Nuclear Regulatory Commission Roy Lessy, Esquire Washington, D.C. 20555 of ^:& o r E :e itive i " al Di> tor i.i

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l e Ut . . <uca D , , r i z, Atente Safel'y .% 1,1 c e ns i n g Appeal Board U.S. Nuclear Regttlatory Commission Washington, D.C. 20555 C. i l

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Ellyn R. Weiss

• mailed postage pre-paid

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