ML19332D570

Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit

ML19332D570
Person / Time
Site:	Seabrook
Issue date:	11/17/1989
From:	George Minor, Sholly S MHB TECHNICAL ASSOCIATES
To:
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ML19332D561	List: ML19332D560 ML19332D566 ML19332D570
References
OL, NUDOCS 8912040157
Download: ML19332D570 (35)

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i UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION _l

,t3, ATOMIC SAFETY AND LICENSING. .. BOARD  :

s In the Matter of .l PUBLIC SERVICE COMPANY OF Docket Nos. 50-443-OL/50-444-OL NEW HAMPSHIRE, ET AL

.(Seabrook Station Unit 1 ,

JO:NT AFFTDAVr" OF GREGO?.Y C. MNOF. AND STEV E V C. SHOI LY '

lEGAR3 NGb" EW F AM>S -: R EYANY:0'S R :viEN3EP 2' 1989 .

- O 'ERATING RCENS EAN :ND H f.' R 20 J iST (P ANTI W1 d MF VT AIR C IOSS-CONb ECT TO cob TAINVMbT BUT SING AIR SYs1dM. VYb-89116),

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l I, Gregory C. Minor, do make oath and say:

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. 1. My name is Gregory C. Minor. I am a Vice President of MHB Technical k Associates. My business address is 1723 Hamilton Avenue, Suite K, San Jose, California 95125. I received a B.S. in Electrical Engineering from the University of California, Berkeley, in 1960 and '

a M.S. In Electrical Engineering from Stanford University in 1966.

L 2. I have over twenty-Sve years of experience in the design, development, research, p

' start-up testing, and management of nuclear reactor systems. From 1960 1976, I worked for General Electric Company in the desiga, development and testing of safety and control systems 8912040157 891117 PDR ADOCK 05000443 O. PDR p ,- -- Tej E -

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4 i for nuclear plants. My responsibilities included equipment and systems design, as well as managetuent of a large engineering group responsible for new control room design.

3. For the past thirteen years,I have been an independent technical consultant. In that capacity, I have participated in a variety of studies addressing nuclear facility economic, management, and safety issues for various organizations, including the Department of Energy / Sand.in National Laboratories, the Swedish Government, and the offices of several states' ,

Attorneys General. I am currently a consultant on several nuclear plant cases in which design, management, and compliance with existing regulations are being investigated.

4. I am a member of the Nuclear Power Plant Standards Committe: for the Instrument Society of America. Also, I participated in a Peer Review Group of the Nuclear Regulatory Commission's Three Mile Island Special Inquiry Group. Further details of my qualifications and professional experience are summarized in my Statement of Professional Ounlifications which is appended to this affidavit as Attachment 1. ,

I, Steven C. Sholly, to make oath and say:

5. My name is Steven C. Sholly. Since September 1985, I have been employed as an Associate Consultant by MHB Technical Associates. My business address is 1723 Hamilton Avenue,' Suite K, San Jose, California 95125.

6. I have been previously employed by the Union of Concerned Scientists as a Technical Research Associate and Risk Analyst from February 1981 to September 1985, and by the Three Mile Island Public Interest Resource Center as Research Coordinator and Project Director from January 1980 to January 1981. .I also have non nuclear experience in the wastewater treatment and science education fields from September 1975 to January 1980. I 2-

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received a B.S. in Education, with a major in Earth and Space Science and a minor in ,

Emironmental Education, from Shippensburg State College (now Shippensburg University),

Shippensburg, Pennsylvania, in 1975. l

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7. For the last nine and a half years, I have been engaged in analyzing technical nuclear safety, management, design, construction, and regulatory issues and providing technical advice to state and local governments (including the States of California, New York, I!!inoit, Pennsylvania, Maryland, Maine, Connecticut, and Massachusetts, and Suffolk County, New York) l and independent organizations on these issues. I have presented testimony concerning these i

issues before the Connecticut Department of Public Utility Control on behalf of the Prosecutorial i

Division and Division of Consumer Counsel, before the California Public Utility Commission on o

behalf of the Division of Ratepayer Advocates, before the Pennsylvania Pub!!c Utility Commission l on behalf of the Office of Consumer Advocate, and before the Massachusetts Department of  ;

L Public Utihties on behalf of the Office of the Attorney General, Commonwealth of Massachusetts. j i

l I have also participated as an expert witness in proceedings before the Atomic Safety and j i

Licensing Board in the Indian Point Special Investigation and the operating license review of the Catawba nuclear plant, and have presented testimony before the United States Congress on l nuclear safety issues. Further details of my experience and qualifications are contained in my L

Statement of Professional Ounlifications which is appended to this affidavit as AttachmenL2 DISCUSSION i

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8. On September 21,1989, New Hampshire Yankee ("NHY") sent a request for license l amendment to the NRC staff requesting a change in Table 3.61 of the Seabrook Unit 1 Technical Specifications, adding Penetration No. X 68 to the list of secondary containment bypass leakage l

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paths.1/ 'Ihis proposed change "results from the addition of cross connect pipingfrom the Plant Instrument Air System, outside containment, to the Containment Building Compicssed Air System, ,

inside Containment." 2/ .

9. NHY correctly describes the function of the Containment Building Compressed Air System as follows: 3/

The Containment Building Comp:essed Air System supplies the instrument air requirements of pneumatic instruments and actuators ,

within the Containment Building. Airfor the system is supplied by two compressors located inside the Containment Building. One of the major

• components that relies on the Containment Buildmg ed Air System is the Primary Component Cooling Water (P System containment isolation valves. The operabilly of the PCCW stem is essential to the operation of the Reactor Coolant Pumps. Loss of the i Containment Compressed Air System will ultimately cause aforcedplant shutdown. 4/

10. According to NHY, the purpose of the license amendment is to " preclude the potential of a forced shutdown as a result of loss of the Containment Building Compressed Air .

. System", by cross-connecting a "back up" air supply system between the Plant Instrument Air i

1/ New Hampshire Yankee Letter No. NYN-89116, dated 21 September 1989, from Ted C.

Feigenbaum to the NRC Document Control Desk,

Subject:

" Request for License

. Amendment; Plant Instrument Air Cross Connect to Containment Building Air System".

2/ 11, at 1.

l JJ New Hampshire Yankee I.etter No. NYN-89116, dated 21 September 1989, from Ted C. '

l Feigenbaum to the NRC Document Control Desk,

Subject:

" Request for License Amendment; Plant Instrument Air Cross Connect to Containment Building Air System",

Enclosure 2, at 1.

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.4/ NHY's proposed amendment and related documentation fails to enlain why failure of the Containment Building Compressed Air System will cause a forcec plant shutdown. The reason is that this system provides compressed air to air-operated containment isolation l valves for the Primary Containment Cooling Water (PCCW) system. These containment isolation valves fail closed on loss of air pressure. The PCCW system provides cooling to l

the thermal barriers on the reactor coolant pumps. If thermal barrier cooling is lost, the .

reactor coolant pumps must be shut down within 3-10 minutes to avoid pump damage. Sr.g, '

Seabrook FSAR, Seetion 7.1.2.5, pages 7.1-22 to 7.2-23.

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i Sys:em and the Containment Air System. ff NHY also states that " plant reliability will be enhanced" by providing this backup air system. ff

11. As discussed in Pars.12 and 13 below, the proposed license amendment is illogical.

It will not preclude the potential for a forced shutdown because the backup air system will not be in use when the plant is in operation. Moreover, NHY provides no additional justification for its assertion that plant reliability will be improved by implementation of the proposed license amendment. In fact, the proposed license amendment adds a new source of potential containment leakage without any apparent compensating safety benefits.

12. The on1y way the proposed license amendment and related design change could preclude the potential for a forced plant shutdown as a result of the loss of the Containment Building Compressed Air System would be if the proposed design change were operable during Modes 14 (i.e., including power operation in Modes 1 and 2). As both NHY's proposed license amendment request and the NRC staff's related Federal Recister notice make clear, the air cross-connect will not he operable in Modes 1-4 (the air-operated isolation valve in the cross-connect line will be disarmed and the valve will be administratively controlled in the locked closed position in Modes 1-4),2/ but will instead anh be available in Modes 5 and 6 (cold shutdown and

' refueling, respectively). Accordingly. it is impossible for the proposed design change to preclude a olant shutdmvn due to failure of the Containment Building Compressed Air System since the 5/ Ibid ff New Hampshire Yankee Letter No. NYN-89116, dated 21 September 1989, from Ted C.

Feigenbaum to the NRC Document Control Desk,

Subject:

" Request for License Amendment; Plant Instmment Air Cross Connect to Comainment Building Air System", at 1.

2/ Indeed, halb NHY's " Safety Evaluation" of the proposed design change and the NRC staff's Federal Register notice state quite clearly, "Tius cross-connect will not be used during Modes 14...". Seg, New Hampshire Yankee Letter No. NYN-89116. dated 21 September 1989, from Ted C. Feigenbaum to the NRC Document Control Desk,

Subject:

" Request for License Amendment; Plant Instrument Air Cross. Connect to Containment Building Air System", Enclosure 2, at page 2; and 54 Federal Register 43634,26 October 1989.

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cross-connect will not be onerable until the olant is altendv shut down. Thus, even after Implementation of the oroposed design change, failure of the Containment Building Compressed Air System will Mill lead to closure of the air operated Primary Component Cooling Water

.(PCCW) System isolation valves, thus depriving the reactor coolant pumps of thermal barrier f cooling and necessitating the shut down of the reactor coolant pumps and the reactor. Moreover, It should be noted that the operability of the proposed air system cross-connect will have no ,

impact on the reliability of the PCCW system since this system it not even required to be 5

OPERABLE in Modes 5 and 6,8/ the only modes in which the proposed cross-connect will be available (according to NHY and the NRC staff). Hence, the asserted underlying technical i rationale for the proposed license amendment and related design change (i.e., avoiding a forced

- reactor thut down and improving plant reliability) is without a technical basis, and the proposed

= amendment and design change are illogical. .

13. Aside from their erroneous statement that the proposed backup air system would avoid a forced reactor shutdown or improve plant reliability, neither NHY nor the NRC staff cite ,

any other asserted safety benefit accruing as a result of approving the proposed amendment. .

-Accordingly, there is no identified benefit to implementing the proposed design change that would justify exacerbating the potential for containment leakage in the event of an accident. 2/  ;

14. In cur view, the illogical nature of the requested design change raises serious questions about the sufficiency of the safety analysis that was purportedly performed in support of this proposal.

8/ Seabrook Technical Specification 3.7.3.

l 2/ Although NHY plans to use an existing containment penetration, the additional equipment added to the inboard and outboard sides of the cenetration would result in an increase in l the potentialleakage paths and the likelihood ofleakage under accident conditions.

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15. NHY seeks to effect the proposed design changes through an amendment to its low power operating license. However, the proposed amendment is unnecessary for and irrelevant to

. low power operation. In fact, the application's analysis of whether 10 CFR 50.92 is satisfied is Inddressed to conditions under full power operation. Moreover, NHY states that the cross-connect

will not be implemented until the first refueling outage.10/ Surely NHY does not propose to

' refuel at the conclusion of low power testing, so NHY must be referring to refueling following full power operation for the first fuel cycle.

16. NHY's 21 September 1989 letter makes reference to a review of the proposed amendment conducted pursuant to 10 CFR 50.59 and NHY's conclusion based thereupon that the proposed amendment does not involve an "Unreviewed Safety Question". The proposed amendment is not appropriate for disposition under 10 CFR 50.59 since it does indeed require a change in the Technical Specifications. The requirements of 10 CFR 50.59(a)(1) clearly state that design changes can be made without prior Commission approval "unless the proposed change, test 4 or experiment involves a change in the technical specifications incorporated in the license or an ,

unreviewed safery question". Moreover, we do not consider the safety analysis performed by NH to be sufficient basis to conclude there is no unresolved safety question.

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- 17. Moreover, NHY's proposed license amendment is technically flawed because it fails to address the crucial question of whether the proposed design change could increase the probability of accidents already reviewed or introduce new accidents not already reviewed; nor i does the request provide sufficient information such that the NRC staff could independently I . evaluate these matters. NHY's purported evaluation " utilizing the criteria specified in 10 CFR 50.92"is framed entirelv in terms of the consequences of accidents, and provides no discussion of i

19/ New Hampshire Yankee letter No. NYN-89116, dated 21 Se tember 1989, from Ted C.

- Feigenbaum to the NRC Documem Control Desk, S ect: "Re$ test r Licerue Amendrnent; Plant Instntment Air Cross Connect to Containment Bui. ding ir System",

Enclosure 2, at 1.

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i accident probabilities other than the unsupported statements that accident probabilities will not

'be affected. Such conclusory statements, with no stated underlying technical basis, cannot be accepted in lieu of an actual analysis. For example, NHY does not identify which accidents were evaluated (if any), their probability before and after the modification, or any other factor related to the probability of accidents end how they may be affected by the proposed design change. No basis is provided to accept NHY's conclusory statement that no significant changes in probability occur as a result of the design change.

18. Physically cross-connecting the otherwise independent Containment Building Compressed Air System and the ex-contaimnent air system raises systems interactions questions which have not heretofore existed. Neither the NHY nor the NRC staff provide any indication that the results of the combined failure of the systems and components served by the compressed air systems inside and outside the containment are acceptable from a safety standpoint. Indeed, neither NHY nor the NRC staff even identify which instruments, components, and systems would l

be affected by the failure of the two air systems. Since the NHY proposes to cross connect these ,

two systems, such an evaluation should, as an absolute minimum, be required, but neither NHY's license amendment request nor the NRC staff's Federal Register notice provide the slightest indication that such considerations have been addressed. Neither NHY nor the NRC staff have provided a demonstration that safety systems will not be impacted by the failure of the air systems.

19. In conclusion, NHY's license amendment request of 21 September 1989 (NYN -

89116) should be denied as being without technical merit and as proposing a change which would exacerbate a containment leakage path without any corresponding safety benefit. Moreover, the proposal is neither logical nor accompanied by an adequate analysis of the potential impacts of

, the proposed changes on plant safety.

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- Signed under tlie pains and penalties of perjury this 17th day of November 1989.  !

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Gregory C. Minor j i

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$tcVen C. $ holly State of- CE On this the b day of U N M b N 19 bef ore me, I - County of N' M ' ON .

5 I i the undersigned Notary Public, perdonally appeared ',  !

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. Proved to me on the ba6is of SatisfaCloryevidence ]

__ W h Esem5estJD.1M3 to be the person (s)whose name(s) N subscribed to the {

within instrument, and SCknowledged that M executed it. 'b WITNESS my nand and official seal. . f; DT >

Nothry's Segnature j osNanAt acuseowt40GH$Nt f oned 7t t0062 MAtioNAL Notamv AS40C;AtloN e 230tt vemues trie. e vooeciana Hme.CA 91ll6-

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ATTACHMENT 1 Statement of Professional Qualifications Gregory C. Minor

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PROFESSIONAL QUALIFICATIONS OF GREGORY C. MINOR

GREGORY C. MINOR l MHB Technical Associates 1723 Hamilton Avenue -

Suite K San Jose, California 95125

.(408) 266 2716

' EXPERIENCE:

1976 to PRESENT  ;

Vice-Prealdent . MMB Technien1 Atanciaten San .fose. California i

' Engineering and energy consultant to state, federal, and private organizations and individuals.

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' Major activities include studies of safety and risk lavolved in energy generation, providing technical 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 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 Inouiry Group (Rogovin Committee). Actively involved in .

the Nuclear Power Plant Standards Committee work for the Instrument Society of America (ISA).  :

1972 1976 y

' Manneer. Advanced Control and Instrumentation Eneineerine. General Electric Comnanv.

Nuclear Fnerav Division. (lan Jnae California 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. ' Responsibilities included l, coordinating and managing and design and development of control systems, 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 short term solutions to field problems. The disciplines involved included electrical and me.

chanical engineering, seismit design and process computer control / programming, and  ;

L equipment qt'alification.

1970 1972

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Manneer. Renetor Control Svstems Desien. Genernt Electrie Comnanv. Nuclear Enercy Division. San Jose. Californin Managed a group of seven engineers and two support personnelin the design and preparation of the detailed system drawings and control documents relating to safety and emergency

systems for nuclear reactors. Responsibility required coordination with other design

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organizations and interaction with the customer's engineering personnel, as well as regulatory l

personnel.

1 % 3 1970 Dnism Encineer. General Electric Comeanv. Nuclear Encrev 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.

4 Performed lead system design function in the design cf a major system for measuring the power generated in nuclear reactors. Other responsibilities included on site checkout and r

-testing of a complete reactor control system at an experimental reactor in the Southwest.

Received patent for Nuclear Power Monitoring System.

1960 1963 .

Advanced FnMneerina Program. Genernt Electric Comnany Antianments in Wnthinaton.

ralifornia. and Arirnna

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Rotating assignments in a variety of disciplines:

. Engineer, reactor maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.

. Design engineer, Microwave Department, Palo Alto, CaEfornia. Work on design of cavity couplers for Microwave Traveling Wave Tubes (TWT).

- Design engineer, Computer Department, Phoenix, Arizona. Design of core driving circuitry. . .

. Design engineer, Atomic Power Equipment Department, San- Jose, California.

Circuit design and analysis. .

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

. . Technical Staff . Technical Military Planning Operation. (TEMPO), Santa Barbara, California. Prepare anelyses of missile exchanges.

. During this period, completed three year General Electric program of extensive education in advanced engineering principles of higher mathematics, probability and analysis. Also completed courses in Kepner.Tregoe, Effective Presentation, Management Training Program, and various technical seminars.

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I ' EDUCATION University of California at Berkeley, BSEE,1960. .

Advanced Course in Engineering three year curriculum, General E!cetric Company,1963. ,

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Stanford University, MSEE,1966.

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HONORS AND ASSOCIATIONS

- Tau Beta Pi Engineering Honorary Society

- Co-holder of U.S. Patent No. 3,565 760,'Nudear Reactor Power Monitoring System,"

February,1971.

. Member: American Association for the Advancement of Science.

- Member: Nudear Power Plant Standards Committee, Instrument Society of America.

I PUBUCATIONS AND TESTrMONY

1. 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," l

' NEDO 10658, presented at International Nuclear Industries Fair and Technical Meetings, October,1972, Basle, Switzerland. ,

3. The above article was also published in the German Technical Magazine, NP, March,1973.

4. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee on Atomic Energy, Hearing held February 18,1976, and published by the Union of Concerned Scientists, Cambridge, Massachusetts. ,

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5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly Cornmittee on Resources, Land Use, and Energy, March 8, . 976.

6. Testimony of G. C. Minor and R. B. Hubbard before the California State Senate Committee on Public Utilities, Transit, and Energy, March 23,1976.

.r 7. Testimony of G. C. Minor regarding the Grafentheinfeld Nuclear Plant, March 16 17, 1977, Wurzbuerg, Germany.

8. Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21,1977.

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' The Risks of Nuclear Power Reactors? A Review of the NRC Renetor Sefety Study WASH.

9. ' l 1400 (NUREG 75/014.), H. Kendall, et al, edited by G. C Minor and R. B. Hubbard for the Unicca of Concerned Scientists, August,1977.

Swedish Reactor Safety Stude Barseback Risk Aucument. MHB Technical . Associates,  !

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January,1978. (Published by Swedish Departmet ofIndustry as Document Dsl 1978:1) l 1

11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13,1978, Inu of Coolant Accidents: Their Probability and Consecuence. ]

12. Testimony by G. C. Minor before the California' 1.egislature Assembly Committee on  ;

. Resources, Land Use, and Energy, AB 3108, April 26,1978, Sacramento, California.

N 13. Presentation by G. C Minor before the Fec'eral Ministry for Research and Technology

. (BMFT), Meeting on Reactor Safety Researe,h, Man / Machine Interface in Nuclear Renetors.

August 21, and September 1,1978, Bonn, Germany,

14. Testimony of G. C Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety and Licensing Board, September 25,1978, in.the matter of Black Fox Nuc! car Power Station Constructim Permit Hearings, Tulsa, Oklahoma.

15. Testimony 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 legislature, Special Joint Committee on Nuclear Energy, Imnlications of Three Mile teland Accident for Nuclear Power Plants in Michigan, October 15,1979.

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A Critical View of Reactor Safety. by G. C Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nuc! car Reactor Safety, January 7, 1980, San Francisco, California.

18. The Effects of Aoina on Safety of Nuclear Power Plante paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1,1980.

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Minnesota Nuclear Plants Gaseous Emissions Studv. 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 tnatter of Long Island Lighting Company Temporary Rate Case, case # 27774 September 22,1980. .

21. Direct testimony of Dale G. Bridenbaugh and Gregory C Minor before the New York State -

Public Service Commission, Kai<er Enrincers Power Corocration Review of Shoreham Nuclear Power Station Costs and Schedule. in the matter of Long Island Lighting Company Temporary

,H Rate Case, Case Number 27774, September 29,1980.

22. Svstems interaction and Sincle Failure Criterion. MHB Technical Associates, January,1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

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23. ' Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Bod of Public Utilities, Oyster Creek 1980 Refueline Outane Investication. in the matter of ths Petitica of Jersey Central Power and Light Company for approval of an increase in the rates for electrical

service and adjustment dause and factor foe such service, OAL Docket No. PUC 3518 80, BPU

• , Docket Nos. 804-285,807-488, Pebruary 19,1981.

24. - Testimony of G.C. Minor and D.G. Bridenbaugh on PORV's and Pressurizer Heaters. Diablo Canyon Operating License hearing before AFLB, in the matter of Pacific Gas and Electric Company (Diablo Canyon Nadear Power Plant, Unhs 1 and 2), Docket Nos. 50-275 OL,50- l 323-OL, January 11,1982. l

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25. Testimony of G. C. Minor and R. B. Hubbard on Emercenev Resnonse Planning, Diablo Canyon Operating License hearing before ASLB, Docket Nos. 50-275-OL,50-323-O' , January II,1982.

26. Svstems Interaction and Rinole Failure Criterion Phase II Rer, ort. MHB Technical Associates, February 1982, prepared for and available from the Swedish Nuclear Power Inspectorate, j Stockholm, Sweden.

27. Testimony of G. C. Minor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwood on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in 'the matter of Long Island .

Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Contention 7B, Safra 3

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gapineneinn and Svstems interaction. Docket No.50-322 OL, April 13,1982.

28. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham  ;

Nuclear Power Station, Unit 1, regarding Su%Ik County contention 11. Pantive Mechanical Valve Failure. Docket no.50-322-OL, April 13,1982.

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29. - Testimony of G. C. Minor and R. B. Hubbard on behalf of Suffolk County, before the Atomic L

i Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nudear .

l Power Station, Unit 1, regarding Suhlk County Contention 27 and SOC Contention 1 Post- l

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1 - Aceirient Manitorina Docket No.50 322 OL, May 25,la82.

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30. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board,in the matter of Long Island Lighting Company, Shoreham L Nuclear Power Station, Unit 1, regarding Suffolk County Contention 22. SRV Test Procram.

b Docket No. $0-322-OL, May 25,1982.

Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the 31.

Atomic Safety and Licensing Board,in the teatter of Long Island Lighting Company, Shoreham -

Nudear Power Station, Unit 1, regarding Reduction of SRV Challenus, Docket No. 50-322 OL, June 14,1982.

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32. Testimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing L

j; Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, regarding Environmental Oualification. Docket Nc,. 50-322-OL, January 18,1983.

33. Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Office of Consumer Advocate, Recardine the Cost of l

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j Cggstructina the Susouchanna Steam Electric Station. Unit 1. Re: Pennsylvania Power and Light, Docket No. R 822189, March 18,1983, 34 Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of l l

Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Safety Classification I and Systems Interaction (Contention 7BL Docket No. 50 322, March 23,1983. J

35. Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Clean-up of Uranium Mill Taihngs. June 20,1983.

p 36, Svstems Interaction and Sinole Failure Criterion: Phase 3 Renort. MHB Technical Associates, i

m June, ,1983, prepared for and available from the Swedish Nuc! car Power Inspectorate, Stockholm, Sweden.

37i Systematie Evaluatinn Pronram: Status Renort and initini Evaluation. MHB Technical f Associates, June,1983, prepared for and available from the Swedish Nuclear Power L Inspectorate, Stockholm, Sweden.

38. Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and l Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Fmeraancy Plannina - Ev=enation Times and Dnmen (Contentions 65.

23.D and 23.HL Docket No. 50-322 01 3, November 18,1983.

39. Testimony of G. C. Minor, Sizewell 'B' Power Station Public Inquiry, Proof of Evidence Ranarana tafety Iguns, December,1983. ,

- 40. Testimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard sad G. C. Minor before the State of New York Public Service Commission, PSC Case No. 27563,in the matter of Long Island Lighting Company Proceeding to Invaatiente the Cost of the Shoreham Nuclear Generatina Facility - Ph== II. on behalf of County of Suffolk, February 10,1984. .

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41. Tesdmony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Atomic g Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nuclear J .-

Power Station, Unit 1, on behalf of Suffolk County Regarding Emereency Plannina - Shelterinn l

I (Contention 61), Docket No. 50-322 OL, March 21,1984.

42. : Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G. Bridenbaagh before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting company, 4'

' - Shoreham Nuclear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine. Docket No. R.322 0L,' March 21,1984.

43. Revised Testimony of Gregory C. Minor before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County regarding Emereenev Planninn - Recovery and Reentry (Contentions 85 and 88L Docket No.50-322 OL, July 30,1984.

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, 44.' Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the A:omic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding Low Power Hearines - Seismic Canabilities of AC Power Sources. Docket No. 50-322 OL, July 1984.

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45. Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Gregory C. Minor, Before the New York State Public Service Commi:sion, PSC Case No.

27563, Shoreham Nuclear Station, Long Island Lighting Company, on behalf of Suffolk County 4, and New York State Consumer Protection Board, regarding IDEstination of the Cost of the Shorchap Nuclear Generatina Facility. October 4,1984.

46. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf -

i of Massachusetts Attorney General, DPU 84145, before the Massachusetts Department of Public Utilitics, regarding Prudence of Exnenditures by Fitchbura Gas and Electric Licht U Comnany for Seabrook Unit 2. November 23,1984,84 pgs.

47. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danic! son and Gregory C. Minor on behalf of Maine Public Utilities Commission Staff regarding Prudence of Costs of Seabrook Unit 2.  ;

Docket No.84-113, December 21,1984.

48. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Suffolk County regarding Shoreham Emeraency Diesel Generator Loads. Docket No. 50-322 0L, January 25, 1985.

49. Direct Testimony of Dale G. Bridenbaugh, Lyna M. Danielson, and Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Docket No. 5030, regarding Prudence of raatral Vermont Public Service Cornaratiana Costs for Seabrook 2. November 11,1985.

50. Surrebuttal testimony of Gregory C. Minor oc bebV of the Vermont Department of Public Service, PSB Docket No. 5030, Prudence of Central bermont Public Service Cornorations Costs for Seabrook 1 December 13,1985.

51. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C.

Sholly on behalf of State of Connecticut Department of Public Utility Control Prosecutorial Division and Division of Consumer Counsel regarding the Prudance of Fwnanditures 2R ,

Milletone Unit 3. Docket No. 83 07-03, February 18,1986.

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52. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding the Prudence of Frnenditures by New Fnaland Power Co. for Seabrook Unit 2. Docket Nos. ER 85-646-000, ER 85-647-000, February 21,1986.

53. Direct Testimony of Gregory C. Minor on behalf of the Prosecutorial Division of CDPUC

' regarding CL&P Construction Prudence for Millstone Unit 3. Docket No. ER-85-720 001 March 19,1986.

54. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts l' Attorney General regarding WMECo Construction Prudence for Millstone Unit 3. Docket No.85-270, March 19,1986.'

55. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behclf of Massachusetts Attorney General regarding WMECo's Commercial Ooeratine Dates and Deferred Canital Additions on Millstone Unit 3. Docket No. 85 270, March 19,1986.

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56. RebuttalTestimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding Rebuttal to New Encland Power Comoanv's Senbrook 2. Docket Nos. ER 85-646-001, ER 85 647 001, April 2,1986.

. 57.' Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine

- Staff of Public Utilities Commission regarding Construction Prudence of Millstone Unit 3. in  ;

the mattet of Maine Power Company Proposed increase in Rates, Docket No.85-212, April 21, 1 1

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~1986.

58. Imolications of the Chernobyl 4 Accident for Nuclear Emercenev Plannino for the State of New York. prepared for the State of New York Consumer Protection Board, by MHB Technical' Associates, June 1986.

4-L 59. Direct Tet.timony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont l j

Department of Public Service, regarding Prudence of Costs by Central Vermont Public Service t Cornoration for Mi11 cone 3. Docket No. 5132, August 25,1986.  ;

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60. Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and Light Company, regrading TMI Reetart and Performance Incentives. (Oral testimony), OAL Docket ,{

No. PUC 7939-85, BPU Docket No. ER851116, September 11,1986. '

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61. ' Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Service, regarding CVPS/NU Cnnstruction Prudence related to Millstone Unit 3. Docket j

No. 5132, November 6,1986..

62. Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont j Department of Public Service, regarding Prudence of Funenditures for Seabrook 1. Docket No. j 5132, December 31,1986.

63.' Direct Testimony of Gregory C. Minor on behalf of Suffolk County, before the Atomic Safety j

and Licensin6 Board, concerning %nrahavn . Protective Actinn Recommendations (Contention ,

EX 361 in the matter of Long Island Lighting Co.npany, Shoreham Nuclear Power Station, Unit 1, Docket No. 50 322-OL-5, February 27,1987. j

64. Direct Testimony of Gregory C. Minor et. al. on behalf of the Statn of New York and Suffolk

County,before the Atomic Safety and Licensing Board, regarding The Seone of the Emernency '

Plannina Exercise (Contentions EX 15 and 161in the matter of Long Island Lighting Company, -

L Shoreham Nuclear Power Station, Unit 1, Docket No. 50-322 OL 5, April 6,1987.

65. Direct Testimony of Gregory C. Minor regarding Emernency Plannina Receotion Centers .

Monitorina and Decontamination. Shoreham Docket 50-322 OL 3 (Emergency Planning), April 13,1987.

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66. Testimony of Gregory C. Minor, Steven C. Sholly et. al. on behalf of Suffolk County, regarding f LILCO's Recention Centers - Plannine Basis. before the Atomic Safety and Licensing Board,in l

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the matter of Long Island Lighting Company, Shoreham Nuc! car Power Station Unit 1, Docket No. 50 322 0L-3, April 13,1987.

67. Rebuttal Testimony of Gregory C. Minor and Steven C. Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Rebuttal to Testimony of Lewis G. Hulmant in the l

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.( l matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Urut 1, Docki.t No. 1 50-322 OL 3, May 27,1987, i

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68. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts

' Attorney General, before the Federal Energy Regulatory Commission, regarding Canal Electric .

Comoany Prudence Related to Seabrook Unit ? Construction Ernenditures. Docket No. ER86-704-001, July 31,1987.

69' Direct Testimony of Dale-G. Bridenbaugt. and Gregory C. Minor before the Pennsylvania Public Utility Commission, Regarding Beaver Vallev Unit 1 197o Outane. Docket No.1 79070318, OCA Statement No. 2, August 31,1987.

70. Oral testimony of Gregory C Minor Before the Illinois Pollution Control Board on behalf of '

Reed Custer Community Unit School District No. 255U, re: Braidwood Cooline Pond September 8,'1988, Case PCB 87 209.

71. Testimony of Gregory C Minor in the U. S. District Court, Brooklyn, New York, September 31, 1988, re: County of Suffolk vs.1 TLCO ct,gL, Case CV 87-646,

72. - GE Reed Renort Safety issue Reviews. Issues 5,10, and 24, prepared by MHB Technical Associates for The Ohio State University Nuclear Engineerir.g Program Expert Review Panel, Public Utility Comminion of Ohio, October 1988. .

73. Direct Testimony and Exhibits of Dale G. Bridenbaugh, Gregory C Minor and Steven C. Sholly on Behalf of Massachusetts Department of the' Attorney General, Re: Pilgrim Nuclear Power Station, Inve<tiantion of Pilarim Outnae. DPU 88 28, November 30, 1988, PROTECTED INFORMATION.

74.' SupplementalTestimony of Dale G. Bridenbaugh, Gregory C Minor and Steven C Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear. Power

- Station,Inveariantion of Pilarim Ontaae DPU 88-28, January 20.1989, Exhibit AG-2. ,

75. Testimony of Gregory C. Minor, U. S. District Court, Brooklyn, New York, February 3,1989, re: County of Suffolk vs.1.TLCO er. al.. Case 87 CIV. 646 (JBW).

76. .Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C Minor and Steven C Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power l 1 Station, Inve<tiaation of Pilarim Quenae. DPU 88-28, February 13,1989, Exhibit AG-74.

l l; 77. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on

' Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Investination of Pilarim Ontaae. DPU 88-28, February 17,1989, Exhibit AG-93. ,

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. ATTACHMENT 2.

Statement of Professional Qualifications

. Steven C. Sholly

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PROFESSIONAL QUALIFICATIONS OF STEVEN C SH0LLY j

9 K. "'

STEVEN C.SHOLLY l

' MHB Technical Associates 4  !

1723 Hamilton Avenue Suite K 1 i

,SanJose, California 95125

, , (408) 266-2716 EXPERIENCE! r September 1985- PRESENT )

Annoeinte - MHB Techa cal Amanciates. 5:an Jnae. r'alirnrnia E ,

Associate in energy consulting firm that specializes in technical and economic assessments of

& energy production facilities, especially nuclear, for local, state, and federal governments and -

private organizations.~ MHB is extensively lavolved in regulatory proceedings and the preparation of studies and reports. Conduct research, write reports, participate in discovery -

process in regulatory proceedings, develop testimony and other documents for regulatory proceedings, and respond to client inquiries. Clients have included: State of California, State of

' New York, State ofIllinois. . ,

February 1981ISeptember 1985

- T=bleal Da=amech Amenelate mad Risk Aam1 vat - Uninn of Cancerned Scientiain Waahineton.

DL Research associate and risk analyst for public interest group based in Cambridge,.

s+ Massachusetts, that spad H- in ==:=3== the impact of advanced technologies on society, '

principally in the areas of arms control and energy. Technical work focused on nuc! car power '

plant safety, with emphasis on probabilistic risk assessment, radiological emergency planning ,

c and preparedness, and generic safety issues. Conducted research, prepared reports and studies, F participated in asiministrative proceedings before the U.S. Nuclear Regulatory Commission, developed testimony, analyzed NRC rule making proposals and draft reports and prepared comments thereon, and responded to inquiries from sponsors, the general public, and the media. Participated as a member of the Panel on ACRS Effectiveness (1985), the Panel on

> Regulatory Uses of Probabilistic Risk Assessment (Peer Review of NUREG 1050; 1984),

Invited Observer to NRC Peer Review meetings on the source term reassessment (BMI 2104; ,

1983-1984), and the Independent Advisory Committee on Nuclear Risk for the Nuc! car Risk .

Task Force of the National Association ofInsurance Commissioners (1984). l p

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- January 1980 - January 1981l Proiect Director and Research Coordinator . Three Mile Island Public Interest Resource Center. Harrisburi Pennsylvanin

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Provided administr'ative direction and coordinated research projects for a public interest group

- based in Harrisburg, Pennsylvania, centered-around issues related to the Three Mile Island 'I Nuckar Power Plant. Prepared fundraising proposals, tracked progress of U.S. Nuclear 1 Regulatory Commission, U.S. Department of Energy, and General Public Utilities activities .

concerning cleanup of Three Mile Island Unit 2 and preparation for restart of Three Mile Island .l Unit 1, and' monitored developments related to emergency planning, the financial health of l General Public Utilities, and NRC rulemaking actions related to Three Mile Island.

July 1978 January 1980-Chief Bioloaical Process Onerator . Wastewater Treatment Plant. Derry Townshin Municinal -

Authority. Hershev. Pennevivani=

Chief Biological Process Operator at a 2.5 million gallon per day tertiary, activated sludge, ,

wastewater treatment plant. ' Responsible for biological process monitoring and control, I' including analysis of physical, chemical, and biological test results, process Duid and mass Dow management, micro-biological analysis of activated sludge, and maintenance of detailed process logs for input into state and federal reports on treatment process and efnuent quality. Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operator. "

Member of Water Pollution Control Association of Pennsylvania, Central Section,1980.

July 1977 July 1978 -

Wastewater Treatment Plant Onerator . Borouah of f anovne.12movne. Penn<vivania Wastewater treatment plant operator at 2.0 million gallon per day secondary, activated sludge, ,

wastewater treatment plant. Performed tasks as assigned by supervisors, including simple -

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' physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system.

September 1976-June 1977 L

Scienee Teacher . West Shore School District. Camo Hill. Pennsylvania Taught Earth and Space Science at ninth grade Icvel. Developed and implemented new course materials on plate tectonics, environmental geology, and space science. Served as Assistant Coach of the district gymnastics team. ,

' September 1975 - June 1976 -

Science Teacher - Carlisle Area School District. Carlisle. Pennsvivania Taught Earth'and Space Science and Environmental Science at ninth grade level. Developed and implemented new course materials on plate tectonics, environmental geology, noise pollution, water pollution, and energy. Served as Advisor to the Sdence Projects Club.

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EDUCATION.

B.S., Education, majors in Earth and Space Science and General Science, minor in Environmental Education, Shippensburg State College, Shippensbteg, Pennsylvania,1975.

. Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg, Pennsylvania,19771978.

PUBLICATIONS:

1. " Determining Mercalli Intensities from Newspaper Reports," Journal of Geolocical Education.

. Vol. 25,1971. i l2 - A Critione of: An Indenendent Aueument of Evacuation Times for Three Mile island Nuclear Power Plant Three Mile Island Public Interest Resource Center, Harrisburg, Pennsylvania, January 1981.

3, A Brief Revicw and Critione of the Rnelef and County Radiolnoiral Emereenev Prenaredness j I

i ll Elaa, Union of Concerned Scientists. prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legislature, Washington, D.C., August 17,1981.  ;

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!; 4. The Ne==ity for a Promet Public Alertina Canahility in the Plume Frnosure Pathway EPZ at Nnelaar Power Plant Ritel Union of Concerned Scientists, Critical Mass Energy Project, .

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- Nuclear Information and Resource Service, Environmental Action, and New York Public In-  !

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L terest Research Group, Washington, D.C., August 27,1981. *

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l 5. ' Union of Concerned Scientists, Inc., Comments on Notice of Proposed Rulemaking, j i Amendment to 10 CFR 50, Appendix E, Section IV.D.3," Union of Concerned Scientists, l: Washington, D.C., October 21,1981. * .

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6. .*The Evolution of Emergency Planning Rules," in The Indian Pnint Book A Briefinn on the Safety Inwatisatinn of the Indian Point Nnelaar Power Plante- Anne Witte, editor, Union of L.

l Concerned Scientists (Washington, D.C.) and New York Public Interest Research Group G4ew York, NY),1982. .

7. " Union of Concerned Scientists Comments, Proposed Rule,10 CFR Part 50, Emergency Planning and Preparedness: Exercises, Clarification of Regulations,46 F.R. 61134,' Union of Concerned Scientists, Washington, D.C., January 15,1982. *

8. Testimony of Robert D. Pollard and Steven C. Sholly before the Subcommittee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, March 29,1982, available from the Union of Concerned Scientists.

, 9. " Union of Concerned Scientists Detailed Comments on Petition for Rulernaking by Citizen's Task Force, Emergency Pbnning,10 CFR Parts 50 and 70, Docket No. PRM 50 31,47 P.R. ,

li 12639," Union of Concerned Scientists, Washington, D.C., May 24,1982.

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10. Supplements to the Tes"imony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned

i. Scientists,before the Subcommittee on Energy Conservation and Power, Committee on Energy 1 3-l

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'and Commerce, U.S. House of Representatives, Union of Concerned Scientists, Washington,  !

D.C., August 16,198' ,

1L Testimony of Steven C Sholly, Union of Concerned Scientists, Washington, D.C., on behalf of the New York Public Interest Research Group, Inc., before the Special Committee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the :

Emergency Radiologic Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.

~ 12. ' " Comments on ' Draft Supplement to Final Environmental Statement Related to Construction  ;

and Operation- of Clinch River Breeder Reactor Plant'," Docket No.' 50-537, Union of -

Concerned Scientists, Washington, D.C, September 13,1982. *

'13. " Union of Concerned Scientists Comments on ' Report to the County Commissioners', by the Advisory Committee on Radiological Emergency Plan for Columbia County, Pennsylvania,"

Union of Concerned Scientists, Washington, D.C, September 15,1982.

14. ' Radiological Emergency Planning for Nuclear Reactor Accidents," presented to Kernenergie Ontmanteld Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, J Washington, D.C., October 8,1982.

15. " Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning,'

presented to the Citian's Advisory Committee to Review Rockland Coun:y's Own Nuclear- .

Evacuation and Preparedness Plan and General Disaster Preparedness Plan, Union of Concerned Scientists, Washington, D.C., November 19,1982.

16. Testimony of Steven C. Sholly before the Subcommittee on Oversight and Investigations, Committee on Interior and Insular Affairs, U.S. House of Representatives, Washington, D.C.,

Union of Concerned Scientists, December 13,1982.

17. . Testimony of Gordon R. Thompson and Steven C Sholly on Commiulon Question Two, Contentions 2.1(a) and 2.1(d), Union of Concerned Scientists and New York Public Interest , ,

Rescarch Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board,in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50 247 SP and 50 286-SP, December 28,1982. *

18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Commission l

Ouestion One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point

-Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos.

l. 50-247 SP and 50 286-SP, February 7,1983, as corrected February 16,1983.

• I 19. Testimony of Steven C Sholly on Commission Question Five, Union of Concerned Scientists i and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commission' Atomic Safety and Licensing Board, in the Matter of Consolidated Edison l:

, Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247 SP and 50-286 SP, March 22,1983. *

20. " Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst," Union of

' Concerned Scientists, Washington, D.C, presented at Critical Mass '83, March 26,1983.

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Testimony of Steven 'C.' ShoUy ( . Emergency Planning and Preparedness at Commercial 4 21.

< Nuc! car Power Plants, Union of Concerned Scientists, Washington, D.C, before the

. Subcommittee on Nuclear Regulation, Committee on Environment and Public Works, U.S.

Senate, April 15,1983, (with " Union of Concerned Scientists' Response to Questions for the Record from Senator Alan K. Simpson," Steven C Shouy and Michael E. Faden).

22. "PRA

_ What Can it Really Tell Us About Public Risk from Nuclear Accidents?," Union of Concerned Scientists, Washington, D.C, presentation to the 14th Annual Meeting, Seacoast Anti. Pollution League, May 4,1983.-

23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radiological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C, June 28,1983. .

24. " Response to GAO Questions on NRC's Use of PRA," Union of Concerned Scientists, Washington, D.C, October 6,1983, attachment to letter dated Octcher 6,1983, from Steven C.

Sholly to John E. Bagnulo (GAO, Washington, D.C).

25. The imnact of " External Events" on Radinineical Emernency Resnonse Plannina .

Considerations. -Union of Concerned Scientists, Washmgton, D.C, December 22, 1983,-

attachment to letter dated December 22,1983, from Steven C Sholly to NRC Commissioner

. James K. Asselstine.

26. Sizewell'B' Public Inquiry, Proof of Evidence on: safety and Waste Mana ement Imnlientions of the Sizewell PWR. Gordon Thompson, with supportmg evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G, *A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR," Steven Sholly and Gordon Thompson, (August 11,1983), and Annex O, " Emergency Planning in the UK and the US: A Comparison,' Steven Sholly and Gordon Thompson (October 24,1983).

- 27. Testimony of Steven C Sholly on Emergency Planning Contention Number Eleven, Union of ,

Concerned Scientists, Washington, D.C, on behalf of the Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units 1 and 2), Docket Nos. 50-413 and 50-414, April 26,1984. *

28. " Risk Indicators Relevant to Assessing Nuclear Accident Liability Premiums," in Preliminary l Renort to the Indenendent Advisory Committee to the NAIC Nuclear Risk Task Force.

December 11,1984, Steven C. Sholly, Union of Concerned Scientists, Washington, D.C L 29. " Union of Concerned Scientists' and Nuclear Information and Resource Service's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning" Union of Concerned Scientists and Nuclear Information and Resource Service, Washington, D.C, Diane Curran and Ellyn R. Weiss (with input from Steven C. Sholly), February 28,1985. *

30. " Severe Accident Source Terms: A Presentation to the Commissioners on the Status of a Review ~

of the NRC's Source Term Reassessment Study by the Union of Concerned Scientists," Union

. of Concerned Scientists, Washington, D.C, April 3,1985.

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$ Accident Source Terms for Light Water Nuclear Power Plants: A Presentation to the

Illinois Department of Nuclear Safety on the Status of a Review of the NRC's Source Term Reassessment Study (STRS)' by the Union of Concerned Scientists,' Union of Concerned Scientists, Washington, D.C., May 13,1985.

W - 32, . The Source Term Debate: A Review of the Current Basis for Predictina Severe Accident Source ,

5 Terms with Snecial Emnhasic on the NRC Source Term Ranuaument Pronram (NUREG-(Elifd, Union of Concerned Scientists, Cambridge, Massachusetts, Steven C. Sholly and Gordon ,

Thompson, January 1986.

33. Di ect Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C.

Sholly on behalf of State of Connecticut Department of Public. Utility Control, Prosecutorial ,

Division and Division of Consumer Counsel, regarding the prudence of expenditures on Mi!! stone Unit III, February 18,1986.

34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.

35. Rcview of Vermont Yankae Containment Safety Study and Analysis of Containment Ventina Lunes for the Vermont Yankae Nuclear Power Plant. prepared for New England Coalition on Nuclear Pollution, Inc., December 16,1986.

36. Affidavit of Steven C. Sholly before the Atomic Safety and Licensing Board, in the matter of Public Service Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 -

Off-site Emergency Planning Issues, Docket Mos. 50-443-OL & 50-444 OL, January 23,1987.

37. ' Direct Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of California Public

- Utilities Commissian, regarding Diablo Canyon Rate Case, PGAE's Failure to Establish Its Committed Design OA Program, Application Nos. 84-06-014 and 85-08 025, Exhibit No.10,935,

' March,1987. ,

38. Testimony of Gregory C. Minor, Steven C. Sholly et. al. on behalf of Suffolk County, regarding LILCO's Reception Centers (Planning Basis), before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, Dociet No.50-322 OL 3, April 13,1987.

39. Rebuttal Testimony of Gregory C. Minor and Steven C. Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Addressing Testimony of lewis G. Hulman), Docket No. 50-322 0L 3, May 27,1987.

40. Review of Selected Aspects of NUREG-1150," Reactor Risk Reference Document," prepared ,

for the Illinois Department of Nuclear Safety by MHB Technical Associates, September 1987.

41. Direct Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of the Pennsylvania Office of Consumer Advocate, before the Pennsylvania Public Utility Commission, Evaluation -

of Beaver Valley Unit 2 Plant Costs, OCA Statement 6, Docket No. R.870651, October 23,1987.

42. Final Renort: Sionificant Factors Affectine the Cost of Beaver Valley Power Station. Unit 2.

prepared for Pennsylvania Office of Consumer Advocate, by MHB Technical Associates, OCA Exhibit 6A, October 1987.

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- 43. Final P enort: Sianificant Factors Affectint ne Cost of Beaver Vallev Power Station. Unit 2.

prepared for Pennsylvania Office of Consumer Advocate, by MHB Technical Associates, OCA -

Exhibit 6A, October 1987.-

44. Surrebuttal Testimony of Richard B. Hubbard and Steven C Sholly before the Pennsylvania Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocate, '

L regarding Evaluation of Beaver Valley Unit 2 Plant Costs, OCA Statement 61, Docket No. R-870651, December 7,1987.

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' 45. Testimony on Diablo Canyon Rate Case, Dacian Onality Anurance. Supplemental and Rebuttal Testimony of Richard B. Hubbard and Steven C. Sholly, on behalf of the California Public Utilities Commission, Division of Ratepayer Advocates, Application Nos. 84-06-014 and 85 08-025, Exhibit No.16,690, September 1988.

46. Testimony on' Diablo Canyon Rate Case, Evolution of OA Reauirements And -Their

- Understantilne By The Nuclear Industrs On=11tv Anurance As A Manaoement Tool. Volumes I and II, Supplemental and Rebuttal Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of the California Public Utilities Commission, Division of Ratepayer Advocate, Application Nos. 84-06-014 and 85-08-025, Exhibit No.16,650, September 1988. ,

t.

.47. GE Reed Report Safety Issue Reviews, Issues 1, 6, and 14, prepared by MHB Technical Associates for The Ohio State University Nuclear Engineering Program Expert Review Panel, Public Utility Comminion of Ohio, October 1988. ,

( 48. ~ Direct Testimony and Exhibits of Dale G. Bridenbaugh, Gregory C. Miner and Steven C Sho!!y on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nudear Power Station, Investigation of Pilgrim Outage, DPU 88-28, November 30, 1988, PROTECTED INFORMATION.

49. Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nudcar Power Station, Investigation of Pilgrim Oe: age, DPU 88 28, January 20,1989, Exhibit AG 2.

1- 50. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on l Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nudear Power Station, Investigation of Pilgrim Outage, DPU 88-28, February 13,1989, Exhibit AG-74.

51. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of Attorney General, Re: Pilgrim Nudear Power Station, ,

Investigation of Pilgrim Outage, DPU 88-28, February 17,1989, Exhibit AG 93.

52. Final Renort: Severe Accidents at Three Mile Teland Unit it Severe Accident Characteristics for Radiolomical Emernency Resnonse Plan Develonment. prepared for Institute for Resource and l Security Studies, February 1989.

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-* Available from the U.S. Nudear Regulatory Commission, Public Document Room, Lobby,1717 H Street, N.W., Washington, D.C.

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fNew Hampshire J NYN- 8 9116 Se er 21, 1989 ,'; g. -

.a United! States Nuclear Regulatory Commission 'g grs,;,Og; Washington.1DC 20555 ,

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. . . .t Attention: Document Control Desk ' M!S

, R'eferences: Facility Operating License NPF-67, Docket No. 50-443 y;- .. m 1 Subjects _ Request for License Amendment; Plant Instrument Air Cross-Connect to Containment Building Air System

.Gentiemens-Pursuant to 10 CFR 50.90 New Hampshire Yankee (NHY) hereby' proposes =to n amend the Seabrook Station Operating License (Facility Operating License NPF-67) by incorporating the proposed' change,'provided herein as Enclosure 1 1 1

,/

~into'the Seabrook Station Technical Specifications. This proposed change 7

' results.from the additic,n of cross-connect piping from the Plant. Instrument '

Air System, outside Containment .to the Containment Building Compressed Air System,7inside Containment. Plant reliability will be enhanced by providing a '

back-up airtsupply; to the Containment Building ~ Compressed Air System.

The basis.for this proposed change-is provided in Enclosure 2 which includes a safety' evaluation. Based upon the information contained in-Enclosure-2, NHY has concluded that the proposed change does not involve an h Unrevleved Safety Question-pursuant to 10 CFR 50.59,lnor does it involve a i

.Significant Hazard Consideration pursuant to-10.CFR 50,92.

(

l New Hampshire Yankee has reviewed'the proposed change-utilizing the

• l criteria specified in 10.CFR 50.92 and has determined that the proposed change would.not 1 Y% :

l/ 1.

) Involve a-significant increase in the probability of consequences i L. :of.any accident previously' evaluated. .The activation of a '

previously' spare piping penetration to the Containment will allow j, utilization of the Plant Instrument Air. System,to. backup the l? -Containment Building Compressed Air System during Modes 5 and 6.

L The Containment Building Compressed Air System is non-safety related and not is relied upon for safe shutdown. The new penetration piping is designed'to Quality Group B. standards and-is subject to testing per 10 CFR 50, Appendix J. The activation of this penetration will'not effect-the existing offsite dosage analysis since the analysis already assumes the maximum possible bypass >

t leakage. The total containment integrated leakage, as well as local leakage rates, will remain within 10 CFR 50, Appendix J, limits.

This cross-connect will'not be used during Modes 1-4, therefore, incoming instrument air will not affect containment peak pressure.

fhh I Ao0 ib New Hampshire Yankee Division of Publk. Service Company of New Hampshire )

P.O. Box 300

• Seabrook, NH 03874 = Telephone (603) 474 9521

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. United' States Nuclear Regulatory Commission September 21, 1989-

-Attention: Document Control Desk Page 2

2. Create the: possibility of a new or different kind of accident from

, any previously evaluated. 'The additional Type 'C' penetrations maximum leakage in conjunction with the combined leakage of the existing Type 'B and 'C' penetrations will not exceed the total leakage allowed by 10 CFA 50 Appendix J for bounding radiation doses to within the-dose guidelines of 10 CFR Part 100 during accident conditions.

3. ' Involve aLsignificant reduction in a margin of safety. The bases-  ;

for the Technical Specifications indicate that allowable leakages will be-consistent with assumptions made in the offsite dose-analyses.

-If you have any questions regarding this request, please contact

'Mr. Richard R. Belanger at (603) 474-9521, extension 4048.

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• Very truly yours,

&{& fc',4 Ted C.'Feigenbaum p Senior Vice President and Chief Operating Officer Enclosures-

.cci Mr. William T.'Russel'. *

' Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road j .

King of Prussia, PA 19406 2 1 x ,

) Mr. Victor Herses, Project Manager Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington, DC 20555 -

Mr. George L. Iverson, Director- i Office of Emergency. Management

. State Office Park south 107 Pleasant Street Concord, NH. 03301 Mr. Antone C. Cerne NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 k

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f; - t Enclosure 1 to NYN-89116

ln PROPOSED TECH 0ICAL SPECIFICATION CHANGE.

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TABLE 3.6-1 (Continued) ('  !

SECONDARY CONTAINMENT BYPASS LEAKAGE PATHS

PENETRATION NO. FUNCTION RELEASE LOCATION i i

..X-37B Chemical and Volume Control Primary Auxiliary Building I (Excess Letdown)

X-38A/76A-~ Fire Protection- Fire Wat?r Pumphouse/ Fire Water Tanks l

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-X-388/76B Combustible Gas Control Main Steam and Feedwater Pipe Chase i

'X-39 Spent Fuel Pool Cooling and Fuel Storage Building  !

n., Cleanup ,

1 1

\~/ X-40A Nitrogen Gas-(Low Pressure) Primary Auxiliary Building l X-408- PRT Sample Primary Auxiliary Building l X-62 Fuel Transfer Tube ' Fuel Storage Building

~

>X Service Air Main Steam and Feedwater ( '- '

4 Pipe Chase l

X-71D/74D Leak Detection Main Steam and Feedwater ,  !

Pipe Chase  !

I HVAC-1 Containment Air Purge Primary Auxiliary Building i

p HVAC-2 Containment Air Purge Primary Auxiliary Building

( ): N.A. Equipment Hatch Outside  ;

N.A. Persennel Hatch Main Steam and Feedwater  ;

Pipe Chase j X-72/75 Combustible Gas Control Main Steam and Feedwater Pipe Chase

- X-68 Instrument Air Main Steam and Feedwater Pipe Chase

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SEABROOK - UNIT 1 3/4 6-6

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f- New Hampshire Yankee September 21. 1989 Enclosure 2 to NYN-89116 _r Backgroundt The Containment Building Compressed Air System supplies the instrument '!

air requirements of pneumatic instruments and actuators within.the

Containment Building. Air for the system is. supplied by two compressors located inside the Containment Building. One of the major components that

. relies on the Containment Building Compressed Air system is the Primary

' Component Cooling Water (PCCW) System containment isolation valves. The operability of the PCCW System is essential to the operation of the Reactor Coolant Pumps.- Loss of the Containment Compressed Air System will ultimately cause a forced plant shutdown.

/m

) Description of' Proposed Channes,

(_/ -i To precluds the potential of a forced plant shutdown as a result of loss

- of.the Containment Building Comprussed Air System, New Hampshire Yankee (NHY) proposes that a backup air supply be connected to the Containment Building Compressed Air System. . The back-up air supply would be a cross-connection between'the Plant Instrument Air System and the Containment Air System. The cross-connect would enter the Containment Building thru an existing Containment penetration, X-68. The penetration will be added to Technical Specification Table 3.6-1 " Secondary Containment Bypass Leakage Paths'.

The proposed change would be implemented in two phases. 'The first phase '

- is scheduled for completion prior to commercial operation and would include the installation of the cross-connect piping from the Plant Instrument Air System to the Containment Compressed Air System. The piping isolation design

vill ~ meet 10 CFR 50, Appendix A General Design Criteria 56, ' Primary ye)

Containment Isolation' by utilizing a , fall-closed air operated valve outside L( N' j Containment and a check valve inside. Containment. The air operated valve's P

automatic open/close function will be disarmed and the valve will be L . administrative 1y: controlled in the locked closed position for Modes 1-4. The i second phase of'this change will provide the instrumentation and electrical changes. required to make the cross-connect operate automatically with Containment Air Systen low pressure and assure post-accident leolation. This phase is scheduled to be implemented prior to completion of the first refueling outage.

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'New Hampshire Yankee September 21, 1989 Safety Evaluation of Proposed Channes New Hampshire Yankee has reviewed the proposed changes utilizing the criteria specified in 10 CFR 50.92 and has determined that the proposed change would not i

Involve a.significant increase in the probability of consequences

~

1.

of any accident previously evaluated. The activation of a previous D -spare piping penetration to the Containment will allow utilization of the Plant Instrument Air System to backup the Containment Building Compressed Air System during Modes 5 and 6. The Containment Building Compressed Air System is non-safety related and a not is relied upon~for safe shutdown. The new penetration piping is I designed to: Quality Group B standards and is subject to testing per

. 10 CFR 50 Appendix J.- The. activation of this penetration will not '

effect the existing offsite dosage analysis since the analysis

-5 (]! / already assumes-the maximum possible bypass leakage. .Th e total i V

containment integrated leakage, as well as local leakage rates, will remain within 10 CFR 50, Appendix J, IJmits. This cross-connect will not be used during Modes 1-4, therefore, incoming instrument air will not affect containment peak pressure.

2. Create the possibility of a new or different kind of accident from any previously evaluated. The additional Type "C" penetrations maximum leakage in conjunction with the combined leakage of the existing Type "B and "C" penetrations will not exceed the total .

leakage allowed by 10 CFR-50 Appendix J for bounding radiation doses ,

to within the dose guidelines of 10 CFR Part 100 during accident  ;

. conditions.

3. Involve a significant reduction in a margin of safety. The bases l

- for the Technical Specifications indicate that allowable leakages J l' V will be consistent with assumptions made in the offsite dose

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analyses. 1

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.e. Closing the Feedwater Control Valves .

4.

These valves are routinely tested during refueling outages. -To close them at power would adversely af fect- the operability of

.the plant. The verification of operability of feedwater control valves at power is assured by confirmation of proper operation of the steam generator water level system. The actual actuation function of the solenoids, which provides the closing function,

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l-is periodically tested at power as discussed in Subsection 7.3.2.2e.

The operability of the slave relay which actuates the solenoid, which is the actuating device, is verified 'during this test.

Although the actual closing of these control valves' is blocked when the slave relay is tested, all functions are tested to assure that no electrical malfunctions have occurred which could defeat the protective function. It is noted that the solenoids work on the de-energize-to-actuate principle,. so that the. feedwater control valves will fail closed upon either the ' loss of electrical i

power to the solenoids or loss of air pressure.

Based on the above, the testing of the isolating function of feedwater ,

h control' valves meets the guidelines of Section D.4 of Regulatory i

Guide 1.22.

f. Main Feedwater Pump Trip Solenoids I

L L No practical system design will permit full trip function testing.

l- . of the feedwater pumps without adversely affecting the safety and operability of the plant. At power, tripping of these pumps .,

would introduce a steam generator level transient, resulting in

,- unnecessary trip of the plant from low-low steam' generator level.

! Hence,.the complete trip functions will be routinely tested during re-fueling outages and/or as required by Technical Specifications.

However, the high pressure and low pressure stop valves of the feedwater turbines can be tested during power operation. A 2-way

' solenoid valve is included on each stop valve assembly. When L. energized, this allows each stop valve to be test stroked with l

the turbine in service to ensure that the stop valve stem is l' .not' stuck. - The LP stop valves are only partially closed. A limit switch.de-energizes the solenoid valve-at test position. Hence, the stop valve will move up and down through the limit switch deadband, as long as the operator holds his finger on the test push button. The HP stop valves are tested for fully closed operation if the equipment operating condition permits.

g. RCP Motor Component' Cooling Water Isolation Valves (Close)

Component cooling water supply and return containment isolation valves are routinely tested during refueling outages. Testing of these valves while the reactor colant pumps are operating introduces an unnecessary risk of costly damage to all the reactor coolant (

pumps. Loss of component cooling water to these pumps is of 7.1-22

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u, economic consideration only, as the reactor coolant pumps are not

,' ' ~ required to perform any safety-related function.

The reactor coolant pumps will not' seize due to complete loss of .;

component cooling. Information from the pump manufacturer indicates that the bearing-babbitt would eventually break down but not so

. rapidly as to overcome the inertia of the flywheel. If the pumps are not stopped within 3 to-10 minutes after component cooling water:is isolated,. pump damage could be incurred. ,

Additional containment penetrations and containment. isolation valves introduce additional unnecessary potential pathways for radioactive _ 9 Lleakage following a postulated accident. Also, since the component' cooling water flow rates and temperatures are about. equal during both plant power operation and plant refueling, periodic tests of these valves during a refueling outage would dupli'cate accident conditions.. ,

Mditionally, ' the possibility of failure of containment isolation is remote because an additional failure of the low-pressure fluid system in addition to ' failure of both isolation valves would have to occur to open a path through the containment.

Based.on the above described potential reactor coolant pump damage incurred with periodic testing of ~the component cooling water containment isolation valves at power, the duplication of at power operating conditions during refueling outages, and since 1) no ,

practical-system design will permit operation of these valves without  !

adversely affecting the safety or operability of the plant, 2) the probability that the protection system will fail to initiate the ,

activated equipment is acceptably low due to testing up to final actuation, and 3) these valves will be routinely tested during refueling outages when the reactor coolant pumps are not operating, l ,

the. proposed' resolution meets the guidelines of Section D.4 of 56, af Regulatory Guide 1.22. ,

h'. Seal Water Return Valves (Close)

Seal return line isolation valves are routinely tested during refueling outages. Closure of these valves during operation would cause the safety valve to lif t, with the possibility of valve

• chatter. Valve chatter would damage this relief valve. Testing of these valves at power would cause equipment' damage. Therefore, these ,

valves will be tested during scheduled refueling outages. As above, additional containment penetrations and containment isolation valves introduce additional unnecessary potencial pathways for radioactive l

- *P release following a postulated accident. Thus, the guidelines 56 of_Section.D.4 of Regulatory cuide 1.22 are met. w-i

1. Chartina Header to Cold Les Isolation Valves v.

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The opening of these valves during the test of the actuating protec-

,,3 tion channel would adversely affect the operability of the plant.

The, probability that the protection system will fail to open these

valves is acceptably low due to testing up to final actuation and the valves are routinely tested during refueling outages.

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