ML17083A862
| ML17083A862 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/22/1981 |
| From: | George Minor AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML16340B670 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8105040500 | |
| Download: ML17083A862 (28) | |
Text
EXHIBIT .19 UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LTCENSING BOARD In The Matter Of )
)
PACIFIC GAS & ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 O.L.
(Diablo Canyon Nuclear Power )
Plant - Units 1 & 2) )
AFFIDAVIT 'OF GREGORY 'C.'INOR Concerning ISSUES" RELATED TO VESSEL'EVEL'EA'SURZMENT STATE OF CALIFORNIA )
) ss.
COUNTY OF SANTA CLARA )
GREGORY C. MINOR deposes and says under oath as follows; I'. BACKGROUND OF AUTHOR
- 1. My name is Gregory C. Minor. I have twenty years of experience in the design, development, research, start-up, and management of nuclear reactor systems. I worked for sixteen years for the General Electric Company and for the past four years as an independent technical consultant. I was a founder in 1976,
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and I am now vice president of MHB Technical Associates. I received a B.S. in electrical engineering from the University of California, Berkeley, and an M.S. in electrical engineering from Stanford University. My sixteen years with G.E. involved the design, development, and testing of safety and control sys-tems for -nuclear plants. Since 1976, I have participated in a variety of reactor studies addressing nuclear safety issues. I
'am presently a consultant on several nuclear plant cases con-cerning .the adequacy of current designs to meet existing regula-tions. I am a member of the Nuclear Power Plant Standards Com-mittee for the Instrument Society of 'America. Also, I partici-pated in a Peer Rev'iew'roup of the NRC/TMI Special Inquiry Group investigating the'MI 'acci;dent. My complete experience record is appended to this affidavit astt'ach'me'nt 'A.
1X'. PURP'OSE
- 2. The purpose of this affidavit is to define the sub-stantive issues related to the proposed vessel level measurement technique for discerning inadequate core cooling at Diablo Canyon,
'II.'NTRODUCTION
- 3. The TMI-2 operators'nability to detect low vessel water level was exacerbated by lack of a direct reading water level measurement and thus directly contributed to the accident".,
Diablo Canyon presently has no installed instruments to directly
measure the water level in the reactor pressure vessel. The lack of direct measurement greatly limits the ability of the operator to unambiguously detect'the approach of low water level in the reactor core. The NRC's requirements for correc-tion of this deficiency have been expressed in the Lessons Learned Task Force Report (NUREG-0578), the TMI Action Plan (NUREG-0660), and also the Requirements for NTOL's (NUREG-0737).
The Applicant's proposed solution is to install a Westinghouse system which is still developmental and has several deficiencies which may prevent it from providing an -unabiguous easy-to-inter-pret indication of low water lev'el and inadequate core, cooling.
The following information describes the technical issues related to the Applicant's proposed system.
IV. 'ISCUSSION OF ISSUES
- 4. The presently installed instruments Diablo Canyon operators will rely upon for indications of inadequate core I
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cooling (ICC) are the same type of instruments relied upon during the TMI-2 accident, but with a wider range of readout; namely:
wide range reactor coolant pressure, wide range reactor coolant temperature and core exit thermocouples. 1/ There is general agreement that present displays do not provide an indication of vessel water level.
1/ Affidavit of Hoch & Shiffer, at page 2.
- 5. By themselves, the coolant pressure and temperature measurements are not an unambiguous and easy-to-interpret indica-tion of ICC. Considerable analysis and judgement would be needed to determine if ICC conditions existed based on these two para-meters.
- 6. The Applicant plans to use the core exit thermocouple 2/
readings as an indication that ICC has already occurred, in which case the core may already be uncovered and fuel damage may, already be occurring. They would .then use the thermocouples as an indica-tion of the success of their recovery or mitigation processes.
- 7. Thus, the existing devices for ICC indication are inadequate to give the operator warning of pending ICC but are more of a general indication or after-the-fact ICC indication.
- 8. To augment these instruments, the Applicant plans to add a Subcooling Margin Meter (SMM) 3/ and a Reactor Vessel Level Instrumentation System (RVLIS). The subcooling monitor will pro-vide only a gross indication of coolant conditions to warn the operator when there is the possibility of boiling and void for-mation in the primary loop. This by itself is not an indication of the core being uncovered or the fuel being inadequately cooled.
2/ Affidavit .of Muench at page 2.
3/ The NRC cites this instrument as existing instrumentation (see SER Supplement 14 at page 3-18), wher'eas, the Applicant cites it as equipment to be added (see Muench at page 2).
- 9. Thus, aside from the RVLIS, there is no instrument present or planned for Diablo Canyon which provides an unambiguous I
indication of the ~a roach to uncovering the core.
- 10. The westinghouse system'of vessel level measurement proposed for Diablo Canyon is still under development with ongoing testing not scheduled to be completed until November, 1981, and 4/
reports to be provided to the NRC by January, 1982. Despite its untested and unproven status, the RVLIS is planned for instal-lation in Diablo Canyon before fuel load.
- 11. The NRC Staff has conducted only a review of the RVLIS description and concludes it meets the "documentation requirements."
However, they do not make a finding of acceptability of the total ICC system; postponing that review'o some 'time after January, 1982 /
- 12. The RVLIS indication of reactor vessel level does not meet the requirem'ent of being unambiguous and easy to interpret.
There are conditions where the system is described as providing erroneous or uncertain reading of water level. 6/
4/ Letter, Crane to Miraglia (NRC), re: additional clarification of PG&E's resolution of NUREG-0737, Item II.F.2, Mar. 19, 1981, page 3.
5/ NUREG-0675, SER Supplement 14, April, 1981, page 3-70.
6/ Affidavit of Muench at pages 4 and 5.
- 13. The RVLIS system does not provide coverage for all types of transients or accidents and thus might provide ambiguous or misleading information to the operator. Specifically, readings may be misleading under conditions of void redistribution, level swell, coolant pumps being turned on or off, small breaks in the vessel head, and severe accidents such as anticipated transients without scram. (ASS).
- 14. During LOCA's of greater than 6-inch break size,, the
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Applicant admits that both the RVLXS and the core exit thermo-couples may provide ambiguous indications of ICC. There is no assurance that operators will not be, taking manual action during this period. Also, there is"no way for the operator to know if he is in a period of 'ambiguous, erroneous, or reliable indication from his ICC instruments.
- 15. The RVLIS design may have the same single-failure problem as the SMM which relies on a single data processor fed by redundant, inputs and feeding to redundant readout devices.
However, withholding of "proprietary" information makes the Applicant's description of the RVLIS unclear as to the number of data processors and the algorithm used to create the displays.
If there is only one data processor, it is vulnerable to single failure and/or causing erroneous indications on each of the 7/ Ibid 6 at page 4.
redundant displays. If there 'are two process'ors, there -is no indication of how the operator is to deal with a discrepancy in
'the two output displays. This is an ambiguous condition which could easily mislead'r confuse the operator. The system has two additional points of potential single-failure at the vessel penetration points used for sensing pressures for the differential pressure instruments;- Plugging or blockage of these points could provide an ambiguous and erroneous indication.
- 16. The RVLIS data processor(s) and the displays are not req'uired to be qualified for seismic conditions which the plant may be expected to experience: Thus, there is no assurance that the system will survive a severe earthquake. In the. event the data processor fails or one of the'edundant displays fails, there appears to be no failure indication or indication as to which of
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the redundant display devices'he operator is to rel'y upon.'
The result is an ambiguous and/or misleading indication at a time when the opexator may need to rely on the RVLIS.
- 17. I disagree with the'Staff's position that vessel water level indication is not needed for reactor operation at low power. There is no other instrument that the operator can 8/ The NUREG-0737 requirements for Item II.F.2 exempt the data processing device and displays from the full qualifi-.
cation requirements applicable to pose-accident monitoring equipment. This is not consistent with the need to provide a rel'iable and unambiguous indication for the operator in post-accident conditions.
rely upon for indicating an ap'proach toICC'. 'ne cannot rule out the possibility of accidents, even at low power, which will require swift and accurate operator responses. The Staff's judgement is that there will be time for the operator to make the necessary diagnoses for mitigation of an accident. 9/ Con-sidering the fact that some safety systems will be disabled for the low po~er tests 10/ and the plant is in the shake-down phase, the RVLIS should be available for the operators'se. Further, if the low power test phase is to be used by the Applicant as additional training for their operators, they should have the RVLIS available to experience its capabilities and deficiencies before full power operation.
V. CONCLUSION
- 18. Vessel water leve1'easurement is one of the best indicators of the approach of ICC conditions and is therefore a necessary addition to Diablo Canyon. However, the pxoposed design I
for Diablo Canyon RVLIS is still unproven and appeaxs to have serious deficiencies in its design and its ability to provide unambiguous, easy-to-interpret indications of ICC over 9/ Affidavit of Phillips at page '7.
'10/ Affidavit of Goesnex at page 2.
the full range of operating and accident conditions. A vessel level device of proven capability should be added to Diablo Canyon before the plant operates.
,Further the deponent sayeth not.
April 22, 1981 Gr gory C. Minor Subscribed and sworn to before me this <<',P~ / day of / Icf>, 1981.
OFFICIAL SEAL LINDA L ROBERSON NOTARY PU8LIC - CAuFORNIA SANTA CLARA CO'JIITY My comm. expires AUG 29, 1983 C~ NOTARY PUBLIC My commission expires: .f~- > 7 -FF J ~~
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3 ATTACHMENT A PROFESSIONAL UALIFICATIONS OF GREGORY C. MINOR
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GREGORY C. MINOR MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 (408) 266-2716 E XP E RI EN CE:
19 76 P RESENT l
Vice-President MHB Technical Associates S an Jose, Calif ornia.
Engineering and energy consultant to state, federal, and private oiganizations and individusals. Major activities include s tudies of safety and risk involved in energy generation, providing tech-nical consulting to legislative, regulatory, .public, and private groups and expert witness in behalf of state organizations and citizens 'roups. Was co-'editor of a critique of the Reactor Safety Study (WASH-1400) for the Union of Concerned Scientists and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the NRC/TMI Special Inquiry Group (Rogovin Committee) . Actively involved in the Nuclear Power Plant s tandards Committee work for the Instrument Society of America (ISA) .
1972 l976 Mana er Advanced Control and Instrumentation En ineerin General Electric Com an Nuclear Ener Division San Jose, California.
Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the and operation of'ucIedr reactors. Involved coordination measurement,'ontrol with other reactor design organizations, the Nuclear Regulatory Commission, and custom'ers, both ov'erseas and domestic. Responsi, bilities included coordinating and managing the'esign and development of'on'trol'ystems, safety systems, and new control concepts for use on the next generation of reactors. The position included responsibility for standards applicable to control and instrumentation, as well as the design of'hort-term solutions to field problems. The disciplines involved included electrical and mechanical engineering, seismic design and process computer control/
programming.
1970 1972 Electric
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Mana er Reactor Control' s tems Desi n General Com an Nuclear Ener Division S an Jos'e Cal'if o'rnia.
Managed a group of seven engineers and two support personnel in the design and preparation'f the detailed system drawings and control documents relating to saf ety and emergency systems for nuclear reactors. Responsibility required coordination with other design organizations and interaction with the cus tomer's engineering personnel, -as well as regulatory personnel.
1963 1970 Desi n En ineer General Electric Com an Nuclear Ener Division, I San Jose" Calif ornia.
Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lead design responsibility for various subsystems of instrumentation used to measure neutron flux in the reactor during startup and intermediate power operation. Performed lead system design function in the design of a major system for measuring the power generated in nuclear reactors. Other responsi-bilities included on-site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest. Received patent for Nuclear Power Monitoring System.
1960 1963 Advanced Engineering Program, General Electric Company; Assignments in Washin toh California and Arizona.
Rotating assignments in a variety of disciplines:
Engineer, reactoz maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.
Design engineer, Microwave Department, Palo Alto, Cali-fornia. Worked on design of cavity couplers for TWT's.
Design engineer, Computer Department, Phoenix, Arizona.
Design of core driving 'circuitry.
Design engineer, Atomic Power Equipment Department, San Jose, Calf fornia. Circuit design and analysis.
Design engineer', Space Sys tems Department, Santa Barbara, California. Prepared contzol portion of satellite proposal.
Technical S taf f Technical Milita'ry Planning Operation.
(TEMPO), Santa Barbara, California. Prepare analysis of mis s ile exchanges .
During this period, completed three-year General Electric program of extensive education in advanced engineering principles o f high-er mathematics, probability and analysis. Also completed courses in Kepner-Tregoe, E f f ecti've Presentation, Management Training Pro-gram, and various technical seminars.
EDUCATION University of California at Berkeley, BSEE, 1960.
Advanchd Course in Engineering - three-year curriculum, General Electric Company, 1963.
Stanford University, MSEE, 1966.
HONORS AND AS SO CI ATIONS Tau Beta Pi Engineering Honorary Society.
Co-holder of U.S . Patent No . 3,565-760, "Nuclear Reactor Power Monitoring System," February, 1971.
Member: American Association for Advance of Science.
Member: Nuclear Power Plant Standards Committee, Ins tru-ment Society o f America.
PERSONAL DATA B orn: June 7, 1937 Married, three children Residence: ' an Jose, Cali fornia
%1 PUBLICATIONS AND TESTIMONY G.C. Minor, S.E. Moore, "Control Rod Signal Multiplexing,"
IEEE Transactions on Nuclear Science, Vol. NS-19, February, 1972.
- 2. G.C. Minor, W.G. Milam, "An Integrated Control Room System for a Nuclear Power Plant," NED0-10658, presented at In-ternational Nuclea'r Industries Fair and Technical Meetings, October, 1972, Basle, Switzerland.
- 3. The above article was also published in th'e German Technical Magazine, NT, March, 1973. If V
- 4. Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Joint Committee on Atomic Energy, Hearings held February 18, 1976, and published by the Union of Concerned Scientis ts, Cambridge, Massachusetts .
- 5. Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976..
- 6. Testimony of G.C. Minor and R.B. Hubbard before the Cali-fornia State Senate Committee on Public Utilities, Transit, and Energy, March 23, 1976 .
- 7. Testimony of G.C. Minor regarding the Grafenrheinfeld Nu-clear. Plant, March 16-3.7, 1977, Wurzburg, Germany.
- 8. Testimony 'of G.C. Minor before the Cluff Lake Board of In-quiry, Regina, Saskatchewan, Canada, September 21, 1977.
- 9. The Risks of Nuclear Power Reactors.: A Review of the NRC Reactor Safet Stud 'ASH-1400 (NUREG-75/0140),:H. Keridall, et al, edited by G.C. Minor and R.B. Hubbard for the Union o f Concerned S cientis ts, Augus t, 1977.
- 10. Swedish Reactor Safet Stud: Blrseback Risk Assessment, MHB Technical Associates, January, 1978. (Published by Swedish Department of Industry as Document Sd? 1978:1)
Testimony by G.C. Minor before the Wisconsin Public Service Commission, February 13, 1978, Loss of Coolant Accidents:
Their Probabilit and Conse uence.
- 12. Testimony by G.C. Minor before the California Legislature Assembly Committee on Resources, Land Use, and Energy, AB 3108, April 26, 1978, Sacramento, California.
PUB LI CATIONS AND TESTIMONY Miriis
- 13. Presentation by G.C. Minor, before the Federal tr for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man/Machine Interface in Nuclear Reactors, August 21, and September 1, 1978, Bonn, Germany.
- 14. Testimony by G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard, before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of the Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.
- 15. Thstim'ony of G.C. Minor, ASLB Hearings Related to TMI-2 Accident, Rancho Seco Power Plant, on behalf of Friends of the Earth, September 13, 1979.
- 16. Testimony of G.C. Minor before the Michigan State Legisla-ture, Special Joint Committee on Nuclear Energy, Im lications of Three Mile Island Accident for Nuclear Power Plants in
~Michi an, 10/15/7$ ~
- 17. A Critical View of Reactor Safet, by G. C. Minor, paper presented to the 'American Association for the Advancement of Science, Symposium on Nuclear Reactor Safety, January 7, 1980, San Francisco, I N California.
- 18. The Effects of A in on*Safet of Nuclear Power Plants, paper presented at Forum on Swedish Nuclear Referendum, S tockholm, Sweden, March 1, 1980.
- 19. Minnesota Nuclear Plants Gaseous Emissions S tud, MHB Technical Associates, September, 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.
- 20. Testimony of G.C. Minor and D.G. Bridenbaugh before the New York State Public Service Commission, Shoreham Nuclear
. Plant Construction Schedule, in the matter of Long Island Lighting Company Temporary Rate Case, September 22, 1980.
- 21. Testimony of G~C. Minor and D.G. Bridenbaugh before the New Jersey Boa'rd of Public Utilities, 0 ster Creek 1980 Refuelin Outa e Investi ation, in the matter of Jersey Central Power and Light Rate Case, February 19, 1981.