ML20040H474
| ML20040H474 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 02/11/1982 |
| From: | George Minor MHB TECHNICAL ASSOCIATES |
| To: | |
| Shared Package | |
| ML20040H468 | List: |
| References | |
| NUDOCS 8202180290 | |
| Download: ML20040H474 (7) | |
Text
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC LICENSING AND SAFETY BOARD In the Matter of the Application of
)
Public Service Company of Oklahoma
)
Associated Electric Cooperative, Inc. )
Docket Nos. STN 50-556 and
)
STN 50-557 Western Farmers Electric Cooperative
)
)
(Black Fox Station, Units 1 and 2
)
AFFIDAVIT OF GREGORY C. MINOR Concerning ECCS ISSUES RELATED TO BLACK FOX STATION STATE OF CALIFORNIA
)
)
ss.
COUNTY OF SANTA CLARA
)
GREGORY C. MINOR deposes 'and says under oath as follows:
f I.
BACKGROUND OF AUTH0R
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l.
My name is Grego1y C. Minor.
I have twenty years of experience in the design,. development, research, start-up and
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management of nuclear reactor systems.
I worked for sixteen l-l
, 8202180290 820212 PDR ADOCK 05000556 0
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years for the General Electric Company and for the past six years as an independent technical consultant.
I am a founder l
in 1976 and vice president of MHB Technical Associates.
I i
received a B.S. in electrical engineering from the University of California, Berkeley, and an M.S. in electrical engineering from Stanford University.
'Since 1976, I have participated in a variety of reactor studies addressing nuclear safety issues for Federal, State, and citizens group.
I am presently a consultant on several nuclear plant cases concerning the adequacy of current designs to meet existing regulations.
I am a member of the Nuclear Power Plant Standards Committee for the Instrument Society of America.
Also, I participated in a Peer Review Group of the NPC/TMI Special Inquiry Group, under the direction of Mitchell Rogovin.
My complete experi-ence record is appended to this affidavit as Attachment A.
II.
PURPOSE 2.
The issue of the adequacy of the ECCS function on BWR's in general and Black Fox Station in particular has j
been the subject of considerable debate and litigation.
Recent evidence has raised additional questions about the ECCS, which, to date, have not been fully resolved.
The purpose of this affidavit is to address these unresolved areas. -
III.
DISCUSSION 3.
The ECCS used on Black Fox to a large extent relies on computer predictions of performance and a series of piecewise or partial tests attempting to verify the'ECCS per-formance.
However, absent a full core test using high-exposure fuel and an accurately simnlated accident condition starting from full power, the piecewise approach of verifying efficacy and design adequacy cannot be assured.
Thus, results of tests or analyses which erode the basis for assumed adequacy, must be resolved or the possible design deficiencies corrected if safe' operation is to be assured.
The recent reports dealing with clad swell (NUREG 0630) and deviant core spray tes't results (Japanese tests) definitely require resolution since theyrdeal with basic questions of cooling geometry of the fuel and cooling flow distribution.
4.
The GE models underpredict the incidence of clad swell and rupture under conditions which are possible in a BWR, l
although not the most likely conditions.
L 5.
GE tries to argue that the conditions covered by the NUREG 0630 curves are not relevant to GE BWR fuel.
l However, there is no discussion of off-normal operation or l
l transient conditions where the fuel.might experience conditions l ~
comparable to those in the NRC curves; conditions which GE r
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now considers "do not warrant application to GE BWR fuel"
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(Hill 0 5).
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4 6.
GE has not addressed the relevance of the NRC curves to inner vs outer fuel rods where the inner rods may not see the effect of a cold shroud which GE claims will reduce the perforation strain (Hill 0 5).
7.
The Staff is seeking deferral of the rupture temperature and burst strain issues as it is too soon to conclude that they conform to Appendix K (Staff 0 8).
8.
Japanese tests showed an uneven distribution of core spray which resulted in inadequate distribution of cooling water to the center fuel bundles.
The tests were on a 60 sector of a full scale core and included steam flow.
9.
The Board Notification dated 12/3/81 points out how the Japanese 60 sector test may contradict the 360 air / water tests.
20.
GE states that "(n)either the Lynn nor the Japanese data is representative of a 360 BWR configuration" (Hill 0 7).
This directly contradicts GE testimony in uthe Black Fox Construction permit Hearings in October 1978 (Tr. 6387-6398), and supports the intervenorsi concerns regarding ECCS and Board Question 2.
GE testified at length as to the representative nature of the Lynn tests and how they could be;used to extrapolate to the 360 configuration and to answer the technical concern expressed in the Board Question.
GE even casts doubt on the reliability of 360 test results by predicting deficiencies in the Japanese 360 tests. (Hill 0 7).
_4
11.
The Staff admits that there is only preliminary data from the Japanese tests.
However,.there i's enough' data t'o conclude that some previous tests in air are not applicable to other BWR ~ configurations in steam.
The Staff has not taken the-necessary step of verifying-that the tests in air for 360 4: *,
configuration is truly representative of a full core 360 test h'
with hot fuel and steam.
12.
Based on the numerous contradictory test results
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and the uncertainty of the applicability of the test results
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- _3 to a full-core hot fuel steam / water configuration, there is no assurance that core spray will provide the ne.cessary cooling
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under worst case conditions, nor'is there assurance the fuel
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cladding -integrity and geometry for cooling will be maintained.
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sayeth not.
Furthe r the deponent Yt+n JGt Gregory C. Minor February 11,.1982-
'i F-Subscribe'd and sworn to before (h-me this day of 8/fresgref 1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of the Application of
)
Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc.
)
and
)
Western Farmers Electric Cooperative
)
Docket Nos.
)
STN 50-556CP (Black Fox Units 1 and 2)
)
STN 50-557CP CERTIFICATE OF SERVICE I, Nancy L. Woods, one of the attorneys for Citizens Action for Safe Energy (C.A.S.E.), certify that copies of the following:
"Intervenors' Response Regarding ECCS Issues" have been served on the persons shown on the attached list by United States Mail, postage prepaid, this 12th day of February, 1982.
f L
L. Wo ds February 12, 1982
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n -
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Sheldon J. Wolfe, Esq.
Mr. Gregory Minor Atomic Safety and Licensing MHB Technical Associates Board Panel 1723 Hamiton Ave.
United States Nuclear Suite K Regulatory Commission San Jose, CA 95125 Washington, D.C.
20555 Andrew T.
Dalton, Esq.
Mr. Frederick J. Shon Attorney at Law Atomic Safety and Licensing 14 37 South Main Street Board Panel Room 302 United States Nuclear Tulsa, Oklahoma 74119 Regulatory Commission Washington, D.C.
20555 Mrs. Ilene Younghein 3900 Cashion Place Dr. Paul W. Purdom Oklahoma City, OK 73112
- Director, Environmental Studies Group Mrs. Carric Dickerson Drexel University Citizens Action for 32nd and Chestnut Streets Safe Energy Philadelphia, PA 19104 P.
O.
Box 924 Claremore, Oklahoma 74017 Docketing and Service Section Office of the Secretary of the Joseph Gallo, Esq.
Commission Martha E.
Gibbs United States Nuclear Frederick C. Williams Regulatory Commission Isham, Lincoln & Beale Washington, D.
C.
20555 1120 Connecticut Ave.,N.W.
(3 copies)
Washington, D.C.
20036 Mr. Clyde Wisner Michael I. Miller NRC Region 4 Phillip P.
Steptoe Public Affairs Officer Isham, Lincoln & Beale 611 Ryan Plaza Dr., Suite 1000 One First National Plaza, Arlington, Texas 76011 Suite 4200 Chicago, Ill. 60603 James H. Thessin, Esq.
Office of the Executive Mr. Maynard Human Legal Director General Manager U.S. Nuclear Regulatory Comm.
Western Farmers Electric Coop.
Washington, D.C.
20555 P.
O.
Box 429 Anadarko, Oklahoma 73005 Dr. John Zink Public Service Company of Okla.
Mr. Gerald F.
Diddle P. O. Box 201 Associated Electric Tulsa, Oklahoma 74102 Cooperative, Inc.
P. O.
Box 754 Hon. Michael Bardrick Springfield, Missouri 65801 Assistant Attorney General State of Oklahoma Mr. Lawrence Burrell State Capitol Building Rt. 1, Box 197 Oklahoma City, Oklahoma 73105 Fairview, Oklahoma 73737
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