ML20078E516
| ML20078E516 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/03/1983 |
| From: | Swiger M CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8310050520 | |
| Download: ML20078E516 (53) | |
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00CHETED US?lRC October 3, 1983 00 -4 Ph :36 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
)
Docket Nos. 50-440
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50-441 (Perry Nuclear Power Plant,
)
Units 1 and 2)
)
APPLICANTS' ANSWER TO OHIO CITIZENS FOR RESPONSIBLE ENERGY MOTION TO RESUBMIT ITS CONTENTION #2 By its Motion To Resubmit Its Contention #2, dated September 16, 1983
(" Motion"), Intervenor Ohio Citizens for Re-4 sponsible Energy ("OCRE") asks the Licensing Board to admit its late-filed proposed contention concerning the reliability of the diesel generators to be used at Perry Nuclear Power Plant
("PNPP").
Because OCRE's Motion fails to meet the criteria for late filing of contentions and further fails to demonstrate adequate basis and specificity, the Motion should be denied.
OCRE's proposed contention states:
[T]he Perry diesel generators are not highly reliable, and, to provide further redundancy, in accordance with GDC 17 (Ap-pendix A to 10 CFR 50), Applicants should install 3 independent diesel generators, with at least 2 different manufacturers, l
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per unit.
IE Information Notices 83,58 (which describes crankshaft cracking and failure of the Shoreham diesel generators, manufactured by Transamerica Delaval) and 83-51 (which describes previous failures of the Shoreham diesel generators and problems at the San Onofre diesels, again supplied by Delaval), the attached news articles, and the reportable deficiencies identified by Applicants, all amply indicate that the Perry diesel generators are not very reli-able and that OCRE's recommendation should be implemented.
The third diesel generator proposed by OCRE for each unit would be a 7000 kW gen-erator from a manufacturer other than Delaval which could act as a ' swing' gener-ator supplying either Division 1 or Division 2 loads in the event that one or both of the dedicated diesel generators failed.
The documents cited above de-tail not only serious failures at the Shoreham Station, but also a pattern of deficiencies and substandard quality that i
threatens the reliability of on-site electric power at PNPP.
Motion at 1-2.
OCRE's original contention also stated that Applicants should install three diesel generators made by two different manufacturers in each unit.
The contention was dismissed with prejudice by the Licensing Board in its Special Prehearing Con-ference Memorandum and Order a's lacking basis and specificity.
See Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2), LBP-81-24, 14 N.R.C.
175, 222-24 (1981)..
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OCRE in its Motion suggests that Applican'ts provided OCRE and the Licensing Board with " misleading" information in opposing the original submission of the contention.
Motion at i
2.
OCRE argues that it was " improper" for Applicants in disputing OCRE's contention to "take credit," id.,
for the third, High Pressure Core Spray ("HPCS") dedicated diesel gen-i erator for each unit.
i OCRE's characterization is grossly distorted and self-serving.
As the Licensing Board pointed out in its Special Prehearing Conference Memorandum and Order,. OCRE's die-
.j sel generator contention was " sorely deficient" in terms of specificity.
14 N.R.C.
175, supra, at 224.
OCRE, with a vague reference to the "St.
Lucie difficulties,"
OCRE's Supplement to its Petition for Leave To Intervene, dated April 30, 1981, at 1, which are entirely irrelevant to the current alleged 1
basis for its contention, claimed simply that Applicants ought to have three independent diesel generators by at least two different manufacturers.
Applicants answered, directing OCRE 4
j to PNPP FSAR $ 8.3, that Applicants had six diesel generators, three for each unit, by two different manufacturers.
Appli-cants' Brief on Contentions of Ohio Citizens for Responsible 4
Energy, dated May 22, 1981, at 4.
Applicants did not address the capabilities of the HPCS diesel generators, nor did they have to in order to answer OCRE's vague contention.
In the special prehearing conference, OCRE "did not respond at all to
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s Applicants' citation of a portion of the FSAR" and was
" ignorant of even the most elementary aspects of the system.
14 N.R.C.
175, supra, at 223.
OCRE cannot be heard to say, two years later, that it was misled about facts which were then readily available in the cited portion of the FSAR.
A.
Timeliness The five factors to be considered in determining whether a petition for a late-filed contention should be granted are set forth in 10 C.F.R. $ 2.714(a)(1).
(i)
Good cause, if any, for failure to file on time.
(ii)
The availability of other means whereby the pe-titioner's interest will be protected.
(iii)
The extent to which the petitioner's participa-4 tion may reasonably be expected to assist in developing a sound record.
(iv)
The extent to which the petitioner's interest will be represented by existing parties.
(v)
The extent to which the petitioner's participa-tion will broaden the issues or delay the pro-ceeding.
The balance of these factors weighs overwhelmingly against OCRE's request to admit its diesel generator contention.
Perhaps the most crucial of the five factors is the re-quirement that intervenors demonstrate good cause for their un-4 timely filing.
OCRE claims that "[g]ood cause exists because i
of the new information concerning the reliability of j i 4
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Transamerica Delaval diesel generators."
Motion at 3.
It is not clear to what "new information" OCRE is referring.
Presum-ably, OCRE is referring at least in part to IE Information Notices 83-58 and 83-51, dated August 30 and August 5,
- 1983, respectively, and the recent newspaper articles related to these Information Notices.
However, the Information Notices and newspaper articles, as explained infra, provide no nexus with the P'NPP diesel generators.
Since they are only tan-gentially, if at all, related to PNPP, they cannot constitute good cause for late filing.
Cf. Iowa Electric Light & Power Company (Duane Arnold Energy Center), ALAB-108, 6 A.E.C.
- 195, 196 (1973) (contentions may not be indiscriminate 1y carried over from other proceedings).
OCRE also acknowledges the existence of and relies on a number of reportable occurrences associated with the PNPP die-sel generators.
Motion at 1-2.1/
Correspondence with the NRC Staff (" Staff") under 10 C.F.R. Part 21 and 10 C.F.R.
S 50.55(e) concerning these reportable occurrences dates back to September 19, 1980.
As of March 25, 1983, written notifica-l tion had been sent by Applicants to the Staff concerning 11 of I
the 13 reportable occurrences.
Final reports had been sent to the Staff concerning 9 of the reportable occurrences by August 1
1/
OCRE states that there have been 11 such reportable occur-rences.
In fact, there have been 13.
Each of the reportable occurrences is specifically discussed infra. !
26, 1982, over a year ago.
Moreover, pursuant to discovery on Issue No. 3 (quality assurance), OCRE in April 1983 was permit-ted to examine all of the Deficiency Analysis Reports ("DARs")
for PNPP, including the DARs at issue here.
Thus, OCRE does not and cannot claim that this information, on which it relies to provide a nexus between the Information Notices and the PNPP diesel generators, is new.
Even if the information were new to OCRE, correspondence relating to these reportable occurrences was part of the public record and available to it.
Under the Nuclear Regulatory Commission's
(" Commission's") Rules of Practice, OCRE was obli-gated to apprise itself of the available information on the PNFP diesel generators.
As the Commission recently stated in Duke Power Company (Catawba Nuclear Station, Units 1 and 2),
CLI-83-19, slip op. at 10-11:
We start with the basic principle that a person who invokes the right to partici-pate in an NRC proceeding also voluntarily accepts the obligations attendant upon such participation.
While we are sympa-thetic with the fact that a party may have personal or other obligations or possess fewer resources than o,thers to devote to a proceeding, this fact does not relieve that party of its hearing obligations.
Thus, an intervenor in an NRC proceeding must be taken as having accepted the obligation of uncovering information in publicly available documentary material.
A second fundamental principle appli-cable here is that there is a substantial public interest in efficient and expedi-tious administrative proceedings.
Taken together, these principles require intervenors to diligently uncover and apply all publicly available informa-tion to the prompt formulation of c,ontentions.
(Emphasis added.)
In short, OCRE was not entitled under the Rules of Practice to wait until the Staff issued its Informa-tion Notices on problems with diesel generators.
Especially in light of the fact that OCRE raised the diesel generator conten-tion earlier in this proceeding, it should have been diligent in uncovering the ample information which was publicly avail-able on the PNPP diesel generators.2/
OCRE fares little better on the other factors to be con-sidered in determining whether to admit its late-fi, led proposed contention.
The second factor concerns the availability of other means to protect OCRE's interests.
As Applicants show infra, OCRE has failed utterly to demonstrate why diesel gener-ator reliability at PNPP is not assured by Applicants' commit-ment to comply with the regulatory requirements and guidance for the design, maintenance, inspection and testing of the die-sel generators.
"/
This Licensing Board's ruling that an intervenor can 2
await scientific publications and key staff documents as focus for its efforts," Memorandum and Order (Concerning Ohio Citizens for Responsible Energy's Late-Filed Contentions 21-26), dated October 29, 1982, slip op. at 4 (emphasis added),
has obviously been superceded by the Commission's decision in Duke Power..
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With respect to the third factor, the extent to which OCRE's participation may reasonably be expected to assist in developing a sound record, OCRE makes the remarkable argument that OCRE's competence on diesel generators is demonstrated by its mere " raising of the vital issue of on-site power reliability."
Motion at 3.
Neither OCRE's mere raising of the issue, nor the fact that the Licensing Board has found OCRE's participation useful on other issues, shows that OCRE has any special competence to litigate diesel generator reliability.
See Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2), LBP-82-ll, 15 N.R.C. 348, 352 (no basis shown for OCRE special competence on core catcher issue).
Finally, OCRE acknowledges that admission of this conten-tion "may somewhat broaden the issues."
OCRE cavalierly dis-misses the question of delay with the remark that "[d]elay of the proceeding is' of no concern...."
Motion at 4.
In sum, OCRE once again shows its lack of regard for the Commission's rules and policies concerning late-filed contentions.
B.
Basis and Specificity.
Even if the balance of factors in 10 C.F.R. $ 2.714(a)(1) weighed in OCRE's favor, which it does not, OCRE would still -
have to provide adequate basis and specificity for its proposed contention.
See 10 C.F.R. 5 2.714(b).
OCRE's proposed conten-tion is totally without basis.
Moreover, OCRE makes only a -
4
s general assertion that diesel generators manufactured by Transamerica Delaval, Inc. ("Delaval") are unreliable without providing a specific nexus to the PNPP diesel generators.
OCRE for its alleged basis relies primarily on IE Informa-tion Notice 83-58.
Information Notice 83-58 describes a crank-shaft failure during preservice testing of one of the Shoreham standby diesel generators and the discovery of cracks in the crankshafts of its other two standby diesel generators.
The Information Notice states that the Staff is presently reviewing the problem, and that "(a]t this time it is not clear to what extent other diesel generators manufactured by Transamerica Delaval are vulnerable to the same or similar failures as these experienced by the Shoreham engines."
IN 83-58 at 2.
The In-formation Notice does point out that the Shoreham diesel gener-ators are eight cylinder in-line engines, while the engines for PNPP and several other plants are of a "V" design and have
.2, 16 or 20 cylinders.
Further, OCRE does not show that the PNPP and Shoreham diesel generators have the same length crank-shafts, the same diameter crank pins, the same torsional stresses, or any other enaracteristics potentially relevant to the cracking problem at Shoreham.3/
3/
In fact, the PNPP diesel generators have V-16 engines with longer crankshafts, larger crank pin diameters, and lower tor-sional stresses than the Shoreham diesel generators.
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The PNPP diesel generators, then, are substantially different pieces of equipment from the diesel generators which have experienced crankshaft cracking at Shoreham.
- Moreover, the Information Notice does not state that crankshaft cracking has occurred in any other nuclear power plant's diesel genera-tors, whether manufactured by Delaval or anyone else; and Ap-plicants are not aware of any such problems.
There is no reason to believe that the crankshaft cracking problem at Shoreham is not limited to that plant, or at least to that particular engine design.4/
OCRE thus provides no nexus between the problem discussed in Information Notice 83-58 and PNPP.
However, OCRE maintains that the documents it cites "de-tail not only serious failures at the Shoreham station, but also a pattern of deficiencies and substandard quality that threatens the reliability of on-site electric power at PNPP" (emphases added).
Motion at 3.
OCRE relies in part on IE In-formation Notice 83-51 to establish this " pattern of deficiencies" relevant to PNPP.
IE Information Notice 83-51 describes some " generic diesel generator problems and corrective action taken."
IN 83-51 at 1 4/
Indeed, the crankshaft cracking at Shoreham could be explained by any number of factors other than faulty design or i
materials, including improper installation or failure adequate-ly to inspect and maintain the diesels.
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These include various problems which were experienced at Shoreham and which were corrected.
to IN 83-51 at 2.
However, the vast majority of items identi-fied in the Information Notice do not relate to Delaval die-sels.
The Information Notice states that "[nlo single common trend can be identified," but that the NRC is simply " concerned about the large number of diesel generator events."
IN 83-51 at 1 (emphasis added).
Thus, the Information Notice does not establish a " pattern of deficiencies" at all, let alone a
" pattern of deficiencies" related to PNPP.
The Information Notice does discuss a design problem reported by Delaval. to IN 83-51 at 3-4.
The problem concerns inadequate lubrication of the turbocharger thrust bearings.
PNPP is one of the plants which Delaval reported as being affected. to IN 83-51 at 4.
However, Delaval has provided Applicants with a modified lubri-cation oil drip system design, as described in the Information Notice, in order to remedy this problem.
Applicants have com-mitted to installation of this system prior to pre-engine start testing.
See Attachment 1 to this Answer.
OCRE has made no claim that this modified system is inadequate.
OCRE also relies on certain newspaper articles which are attached to its Motion.
These articles primarily concern the crankshaft problems at Shoreham.
The August 16th article also addresses Information Notice 83-51.
However, the article :
contains no significant additional information concerning the generic diesel generator problem.
There is nothing in the ar-ticle which could establish a " pattern of deficiencies" or a nexus with the diesel generators at PNPP.
One of the August 24th articles concerns NRC audits and citations of Delaval; but, again, the article creates no nexus with PNPP.
Finally, OCRE attempts to establish a nexus with PNPP by citing several " deficiencies"5/ in PNPP's reportable occurrence file associated with the diesel generators.
Motion at n.1.
OCRE does not discuss these reportable occurrences in any de-tail, and for good reason.
A review of the items in question shows that each reportable occurrence has either been corrected, is in the process of being corrected, or was subse-quently discovered not to be applicable to PNPP.
(1)
DAR 038 concerned a potentially defec-tive link rod.
Inspection showed that the defi-ciency does not exist for the PNPP diesels.
A final report was sent to the Staff on December 10, 1982.
See Attachment 2.
The item was closed out by the Staff in IE Report Nos.'50-440/82-17 and 50-441/82-16, dated January 19, 1983.
(2)
DAR 044 concerned the design problem 4
with lubrication of the turbocharger thrust bearings discussed supra.
A final report was sub-mitted to the Staff on April 15, 1982.
See For the latest correspondence with the Staff on this item, see Attachment 3.
(3)
DAR 056 concerned the potential effects of failure of non-safety-related sensing lines 5/
OCRE does not distinguish between deficiencies and potential deficiencies.
Some of the reportable occurrences i
were only potential deficiencies.
See infra.
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during a seismic event.
This did not involve the diesel generators themselvc_ and was outside Delaval's scope of responsibility.
The matter is part of the Gilbert Associates (the architect /
engineer) work scope and has been resolved by a Gilbert Associates design change.
A revised final report was sent to the Staff on November 15, 1982.
See Attachment 4.
The resolution has been condi-tionally accepted by the Staff with final accep-tance pending review by the Staff's Licensing Division.
See IE Report Nos. 50-440/83-01 and 50-441/83-01, dated February 2, 1983.
(4)
DAR 079 concerned potential leakage dur-ing a seismic event in a check valve installed in the starting air system.
The check valve has been modified and has passed seismic testing.
A final report was sent to the Staff on December 15, 1982.
See Attachment 5.
For the latest correspondence, see Attachment 6.
(5)
DAR 083 concerned the mounting location of the governor lube oil cooler.
Delaval has supplied relocation instructions and will supply remounting materials.
A final report was sent to the Staff on February 12, 1982.
See Attachment 7.
For the latest correspondence, see Attachment 8.
(6)
DAR 083 concerned inadequate Code Data Reports.
No material or equipment modifications were necessary.
A final report was sent to the Staff on July 23, 1982.
See Attachment 9.
The Staff closed out this item in IE Report Nos.
50-440/82-11 and 50-441/82-10, dated September 22, 1982.
(7)
DAR 089 concerned nonconforming piping welds.
All Delaval supplied code piping has been inspected and defective welds repaired.
A final report was sent to the Staff on September 24, 1982.
See Attachment 10.
For the latest corre-spondence, see Attachment 11.
(8)
DAR 099 concerned possible improper cap screw length in the starting air valve assembly.
Applicants have committed to inspecting the capscrews for improper length and replacing them if necessary.
A final report was sent to the Staff on June 28, 1982.
See Attachment 12.
For the latest correspondence, see Attachment 13. -
(9)
DAR 101 concerned potential deteriora-tion of a rubber element used in the governor drive coupling.
Applicants have committed to replace the element or the coupling according to Delaval's recommendations.
A final report to the Staff was sent on August 26, 1982.
See Attachment 14.
(10)
DAR 109 concerned the use of commercial grade wire as Class lE cable in three circuits which may perform safety-related functions.
Ap-plicants are reviewing information supplied by Delaval to determine the significance of the consequences associated with failure of these circuits.
An interim report to the Staff was sent on December 22, 1982.
See Attachment 15.
For the latest correspondence, see Attachment 16.
(11)
DAR 117 concerned piping supports supplied by Delaval not meeting ASME Code require-ments.
Applicants have committed to upgrading the piping supports.
An interim report to the Staff was sent on March 25, 1983.
A final report was submitted to the Staff on July 1, 1983.
See i 7.
(12)
DAR 136 concerned a problem in the design of the diesel generator exhaust piping.
The design problem did not involve Delaval, but was the result'of calculations by Gilbert Associ-ates.
Applicants are investigating possible cor-rective actions to be taken.
An interim report was sent to the Staff on August 30, 1983.
See At-tachment 18.
(13)
DAR 139 concerned the use of non-Class 1E power to operate control devices and use of non-Class lE control components in certain circuits.
Delaval will perform an evaluation to determine if this is a design problem.
An interim report was submitted to the Staff on September 15, 1983.
See Attachment 19.
OCRE's comment that "OCRE suspects that these deficiencies are harbingers of troubles to come" is pure speculation.
Two of the reportable occurrences, including the exhaust piping !
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design deficiency with which OCRE appears most concerned, were j
not even attributable to Delaval.
OCRE has not demonstrated a single problem with the PNPP diesel generators which would threaten their reliability.
Neither has OCRE alleged an inadequacy or breakdown in Ap-plicants' control over Delaval which would allow problems to remain undiscovered.
The fact that some deficiencies have been discovered is irrelevant.
The very purpose of Applicants' QA/QC program and design control program is to discover and correct deficiencies.
As this Licensing Board has otated:
"A i
good, working quality assurance program identifies deficiencies f
for correction.
If deficiencies are reported the system is working; and intervenor cannot fashion an admissible contention.
merely by filing deficiency reports without further explana-tion."
14 N.R.C.
175, supra, at 211.
The reliability of diesel generators is in fact the result of a number of factors, including design, testing and operation requirements, inspections, and maintenance.
Sections 8.3 and 9.5 of the ESAR present extensive design and~ analytical infor-mation about the on-site emergency power. system and its ability to meet all NRC requirements, including the required redundancy and independence, the single failure. criterion, and=the required capacity, capability, and reliability to meet General Design Criteria 17 (Electric Power Systems), 18 (Inspection and Testing of Electrical Power Systems), and 21 (Protection System i s
9 Reliability and Testability).
Nowhere does OCRE attempt to explain why the PNPP diesel generators will be unreliable in i
view of the information on reliability presented in the FSAR.
See 14 N.P.C.
175, supra, at 223.
Neither does OCRE explain how Applicants fail to meet current NRC requirements and design criteria, especially in light of the Staff's finding that Ap-i i
plicants have mot all such requirements and criteria.
j s
The Staff also has approved the raliability establishment 1
testing program for the PNPP diesel generators.
PNPP SER 5 8.3.1; Letter from Youngblood to Edelman, dated September 14, 1983 (Attachment 20).
The purpose of the testing program is to
)
j discover any problems before the plant goes into operation.
The plant will not be all, owed to operate until the testing pro-gram is successfully completed.
It is significant that a
Shoreham's crankshaft cracking problem was discovered during
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its preoperational testing program.
In this regard, it should be noted that the Grand Gulf standby diesel generators, which have diesel en?'.nes identical to PNPP's,. passed the rigorous preoperational testing program.
Grand Gulf's testing program is the prototype testing for PNFl approved by the Staff.
Id.
Grand Gulf's testing experience is 4
obviously more relevant to PNPP than Shoreham's.
3
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For all of the above reasons, Applicants respectfully request that OCRE's late-filed' proposed contention on the
~.- _ _
reliability of the diesel generators at PNPP not be admitted as an issue in this proceeding and that OCRE's Motion be denied.
J Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 8
By:
Jay E.
- Silberg, P.C.
Michael A.
Swiger 4
Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
October 3, 1983 a
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October 3, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
ILLUMINATING COMPANY, E AL.
)
Docket Nos. 50-440 I
50-441 (Perry Nuclear Power Plant,
)
Units 1 and 2)
)
)
)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer to Ohio Citizens for Responsible Energy Motion to Resubmit its Contention #2" were served by deposit in the United States Mail, first class, postage prepaid, this 3rd day of October, 1983 to all those on the attached Service List.
D ub k O t l A. S I' W Michael A.
Swiger DATED:
October 3, 1983 l
t I
Y
ll UNITED STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of y
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
SERVICE LIST Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Glenn O. Bright James M.
Cutchin, IV, Esquire Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Mentor, Ohio 44060 Dr. John H. Buck Terry Lodge, Esquire Atomic Safety and Licensing 618 N. Michigan Street, Suite 105 Appeal Board Toledo, Ohio 43624 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Donald T. Ezzone, Esquire Assistant Prosecuting Attorney
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Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John G. Cardinal, Esquire Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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TITURV E L70TD E L E C T R I C
- L !. U iiiTTD TTYG TDTWATT P.O. S oX $000 o CLEVELANo. oMIO 44101 s TELEPHONE (216) sn 56c0 e ILLuvtNAT6NG slo 0 e 55 FUBLics1UARE
- U DaWyn R. Davidson NsYvYl.?..Nta.sc aso cows auciog ATTACHMENT 1 i
f April 15, 1982 1'
Mr. Ja:es G. Keppler Directer, Region'III l
Cffice of Inspection and Enforcement j
US Nuclear Regulatory Cc==ission j
799 Focsevelt Road l
Glan Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant i
Docket Nos. 50-440; 50-441 Final Report en Lubricating Oil Syste= Defect in Standby Diesel Generators (RDC 24(81))
rear Mr. Keppler:
'This Ic::er serves as the Final Repor: required by 10CFR50.55(e) concerning
- he p :en:ial lubricating oil syste= defect en standby diesel generaters, model
- s?.V16, supplied by Transamerica Delaval.
This was first re;orted c Mr. R. B.
I.andsran cf your effice en December 30, 1980, by Mr. W. J. Kacer of the Cleveland Elec:ric.11u=inating Cc=pany (CEI).
Our Interic Report on this subject was filed en January 27, 1981, and a subsequent letter dated October 22, 1981, also cccce:ned this deficiency.
Tria reper: contains a description of the deficiency, an analysis of the safety implicati 7., and the ccrrective action taken.
- ESCRI?T~OS OF DEFICIENCY Transa-arica Delaval is. supplying feur (4) diesel generator units (Model DSRV16) fcr the Ferry Nuclear Power Plant (PS??) that will be used as a standby pcVer l
source for :he PSPP.
On December 16, 1980, Transamerica Delaval notified the l
We'.e.ar Regula: cry Cerenission under 10CFR21 that a potential defect had been identified centerr.ing lubrication of the thrust bearings of the turbochargers.
This no:ification was transmit:ed to CII by their letter dated December 22, 1980.
The turb: chargers for the 2enera: ors were =anufactured by.he E1'liott Company of 1: c t r.n:4, Pennsylvania.
~ hey were installed on the engines by Transa= erica
- elava*. 2:d lubricated in accordance with Elliott Co:pany recc-endations.
The r y :::ed dciec: exists in the lubricating eil syste= that supplies oil to the le:ts ;er borings.
The design of :he syste permits lubricating oil to flov
- :M harings :n1;. when the engine is running and prevents oil flew to the
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I Mr. Ja=es C. Kepplar April 15, 1982 bearings when the e6gine is in the standby = ode.
The oil seal of the turbocharger is a labyrinth type and is only ef fective when the turbocharger is running.
Because of the possibility of seal leakage when the t,urbocharger is not running 1
(engine standby node), the turbocharger lubricating cil system is bypassed at this ti=e.
The turbocharger thrust bearings cay experience rapid wear because of this lubricating systa= which =ay result in engine non-availability, i
' Currently, the diesel generators are set in place at FNPP with pre-engine start testing new tentatively scheduled for Dece=ber,1982.
ANALYSIS OF THE F.GETY IMPLICATIONS Ix:essive thrust bearing wear, due to inadequate lubrication, could affect engine availability and :hus affect the availability of standby A.C. power supply.
resign Criterion 17 of Appendix A to 10CFK50 and Sectien 8.3.1.1.4 of the PNPP PSAR require an available standby A.C. power supply to provide for safe shut I
drvn of the reacter and to maintain the plant in a safe conditien.
CORRICTIVE ACTION The turbocharger lube oil syste vill be codified so that the turbocharger thrust bearings receive adequate oil during pre"lubing.
This rodificatics will also insure tha: the turbocharger is not overlubed.
- elaval has :cmpleted this modificatien design, and has supplied us with the re:'.-nical inferca:ica and parts list.
Installation of these parts to ec=plete
)'
- he r.:difi::: ion vill be performed, under the direction of a telaval Represen-
- stive, af ter ins:allation of the diesel engines is ec=pleted, and prior to pra-engine start testing.
i i
l Oincerely, M%
s Dalv; R. Davidson Vice President Syste= Engineering ~and Construction
- c:
Mr.
Y.. L. Gildner URC ?.esident Inspector - FUPP Lira::cr, ;nspecticn and Enforcement US Nu: lear Regula: cry Cc==ission
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F.'O. Box $000 CLEVELANo. oMio 44101 TELETHoNE (216) E22.f t00 I.' Lur.4 NATsNG BLoG. - $5 PUBLICSoVARE Sen'ing The Best Location in the Nation ATTACHMENT 2 f3JF?AY R. EDB. MAN Decerber 10, 1982 VICE PR15toENT NUC M A R Mr. James C. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Gicn Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Standby Diesel Generators, Potential Link Rod Deficiency
[RDC 20(80)]
Dear Mr. Keppler:
This letter serves as the Final Report pursuant to 10CFR50.55(e) concerning the potential deficiency involving devel counterbore in the link rod in the Transamerica Delaval Incor-porated (TDI) standby diesel engine.
The Cleveland Electric Illucinating Co:pany originally reported this item to Mr. James Konklin of your office on October 8, 1980.
Subscquent correspondence included our interi report dated November 3,1980, and letters dated
'*;ove=ber 25, 1981, and May 5, 1982.
This letter provides tha results of our evaluation.
/
_ valuation of Deficiency
~
Upon receipt of notification fro: TDI that a 10CTR21 report on this condition had been filed on Septe=ber 19, 1980, the decision was =ade to conduct the =anufacturer's reco=-
nended inspection concurrent with appropriate diesel engine installation activities.
The condition was therefore reported as a potential significant deficiency pursuant to 100FR50.55(e) pending co:pletion of our evaluation.
To co:plete our evaluation an inspection has been performed under the supervision of a TDI service representative in accordance with the TDI reco=mendation dated April 20, 1982.
The results are 'that the link rod deficiency does not exist at the Perry Nuclear Power Plant; therefore the condition is not reportable under 10CFR30.55(e).
Very truly yours, W
Murray R. Edelman Vice President Nuclear Group MRE:pab cc:
Mr. M. L. Gildner NRC Site Office Director g
Office of Inspection'and Enforcement U.S. Nuclear Regulatory Co==ission Uashington, D.C.
20555 U.S. Nucitar Regulatory Coc=ission c/o Docurent Management Branch Washington, D.C.
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Serving The Best Location in the Natiot l#JRP.AY R. EDEl. MAN vice misiotNT ATTACllMENT 3 July 1, 1983 NUCU AR Mr. James G. Keppler
- Regional Administrator, Region III Office of Inspectico and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 1,ubricating Oil System Defect in.
Standby Diesel Generators [RDC 24(81))
Dear Mr. Keppler:
Our letter to you dated January 6,1983, stated that the installation of tubing for modification of the, turbocharger lubricating oil syste= would be ec=pleted by July 1983 for Unit 1 and Septe=ber 1983 for Unit 2.
Presently, 90% of the required p' arts have been received; however, installation g- _
cannot begin until repairs of Code piping velds are ce=pleted.
Ve now anticipate
('-
February 1984.
cc pletion by the following scheduled dates:
Unit 1 - Dece:ber 1983; Unit 2 -
j Picase contact us if you have any questions.
Sincerely, f
977 Murray R. Edelman Vice President Nuclear Group MRE:pab cc:
Mr. M. L. Gildner NRC Site Office Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cc= ission Vashington, D.C.
20555 U.S. Nuclear Regulatory Co= mission c/o Document. Management Branch Vashin' ton, D.C.
20555 g
Records Center, SEE-IN Institute of Nuclear Power Operations 1100 Circle 75. Parkway, Suite 1500
/.tlanta, Georgia 30339
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November 15, 1982 DzMin R. OsWdson ATTACHMENT 4
['N'Ns'ttaa.3 Awe cosstavenow Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Revised Final Report - Nonsafety Sensing Lines on Safety-Related 5
Receiver Tanks [RDC 30(81))
Dear Mr. Kcppler:
This letter serves as a revised final report pursuant to 10CFR50.55(e) con-cerning safety-related receiver tanks for the Standby Diesel Generator Starting Air Sys';em being connected to consafety-related sensing lines through normally open, safety-related valves for both Units I and II.
This,,vas first reported by W. J. Racer of The Cleveland Electric Illuminating Co=pany to R. Warnick of your office on June 12, 1961.
A final report on this subject was originally 9
d submitted to your office on July 13, 1981.
includes a description of the deficiency, an analysis of the This report safety i= plica ~ tion, and a revision to the planned corrective action outlined a
e 9
in our report dated July 13, 1981.
Descrf.ptien of Deficiency f'
Gilbert Issociates, Incorporated (Architect / Engineer for the Perry Nuclear Power Plant) desi n drawinss D302-351 and D352-351, outline the piping syste:
5 f or the Standby Diesel Generator Starting Air System (K-43 Syste=).
The design incorporates two air receiver tanks and starting air compressors per diesel generator.
Esch receiver tank is equipped with an air sensing line which auto =atically starts its corresponding air compressor on low pressure.
The air sensing line includes a manually operated isolation valve. The tank, the =anual isolation valve, and the sensing line up to and including a reducer located downstream of the sanual isolation valve are designed safety-related.
The re=aining portion of the sensing line is designed as nonsafety-related.
Analysis of Safety !=plications Failure of the nonsafety portion of the sensing line during a seiemic event j
in blevdown through the sensing line of the receiver tank. There would result is no assurance with this design that the isolation valve could be manually
(]
cicscd in sufficient ti=e to prevent blevdown of the tank below the minimum Therefore, with these assumptions, the failure of the re:;uired pressure.
naasafety line would impair the starting air safety function.
)
- ,,)
( Q' Corrective Action Plannid In our final report'Idated July 13, 1981, we stated that the existing isoletion valves would be replaced with automatic isolation valves.
After further study, this fix has been revised for reasons of reliability.
The final corrective action vill instead make use of an orifice.
The orifice vill be installed between the manual isolation valve and the reducer in the safety-I.
related portion of the sensing line to limit the rate of blowdown from the receiver tank in the event of a break in the nonsafety portion of the sensing line.
By means of the Control Room Lov Header Pressure Alarm, the operator is now given 30 minutes to isolate the receiver tank before the tank air pressure f alls belee the minimum limit sufficient for 5 diesel engine cranking cycles.
The referenced design drawings have been revised to incorporate the orifice.
Tne design act'ivities have been completed.
If you have any questions, do not
. hesitate to contact us.
Sincerely.
/
o av 4;wa.s Dalvyn R. Davidson Vice President System Engineering ind Construction DRD:pab cc:
Mr. M. L. Gildnct NRC Site Office Director Office of Inspection and Enforce ent U.S. Nuclear Regulatory Cenmission Washington, D.C.
20555 U.S." Nuclear Regulatory Commission c/o Docunent Management Branch Vashington, D.C.
20555 Mr. R. Giardina Power Systens Branch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
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Serving The East Location in the Nation VJF. RAY R. EDELMAN ATTACHMENT 5 vict mtsiosNT wuctz^R December 15, 1982 l'.r. Ja=es G. Keppler Rogional Ad=inistrator, Region III Office of Inspection and Enforce =ent U. S. Nuclear Regulatory Cc==ission 799. Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440, 50-441; Standby Diesel' Generators 11odel DSRV16:
Potential Defect in Starting Air Syste= Check Valve (RDC 43(82))
Dear l.'r. Reppler:
This letter serves as a Final Report pursuant to 10CFR50.55(e) concerning a potential
'~ defect in the standby diesel engines supplied by Transanerica DeLaval, Inc. (TDI).
(
Tna Cleveland Electric Illu=inating Co=pany originally reported this ite= to your office on Dece=ber 18, 1981.
Subsequent correspendence included our interi= report dated January 8,1982, and letters dated February 25,1982,11ay 28,1982 and Septe=ber 1, 1982.
This letter provides results of our evaluation.
LISCRIPTION F DIFICIIhCY In their letter dated November 5, 1981, Transa= erica DeLaval, Inc. reported to the Nuclear Regulatory Cc:=ission that a potential defect reportable under 10CFR21 had been discovered in their diesel engine generator syste=.
The potential defect con-cerns a 1-1/2 inch check valve manufactured by the k'=. Powell Co., Cincinnati, Ohio, installed in the starting air syste= between the starting air co= pressor and the starting air storage tanks.
During seis=ic qualification testing, one of these valves was found to leak.
The valve is classified safety-related and designed in accordance with ASME Code Section III, Class 3.
Tng Ferry Nuclear Power Plant has four diesel generators which inclule this valve, identified as k'=.'Powell Co. Figure 2346, and they are installed in the diesel genera-ter starting air syste= (h44).
The total nu=ber of valves in question at PNPP is eight.
n 4
Mr. Jam 2a G. Kepplar December 15, 1982 7--
p.....
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, Q ANALYSIS OF SAFETI I}TLICATION The function of the subject valves is to allow the starting air co= pressor to charge the air storage tank and then to prevent back flow once the tank is charged. Failure of the starting air _ check valve could result in engine non-availability.
CORRECTIVE ACTION Transamerica DeLaval Inc. has provided CEI with the necessary information for the modification of W=. Powell check valve.
The modified check valve has passed seismic qualification.
The corrective action is to replace the existing disc assembly in the check valve.
Del.aval has ordered the appropriate parts for the modification of the valve. The scheduled date of co=pletion for replacement of the parts is July.1,1983.
~
- ? lease call if there are any additional questions.
Sincerely, f
Murray R. Edelman Vice President 152/11p cc:
Mr. M. L. Gildner NRC Site Office Director Office cf Inspection and Enforcement U. S. Nuclear Regulatory Cc=ission
~
Vashington, D. C.
20555 U. S. Nuclear Regulatory Co=ission c/o Locument Management Branch Washington, D. C.
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MURRAY R. EDEl. MAN July 1, 1983 vict entsistNT ATTACHMENT 6 wucuan Mr. Ja=es G. Keppler Regional Administrator, Region III office of Inspection and Enforce =ent U.S. Nuclear Regulatory Co==ission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Pla:it Docket Nos. 50-440; 50-441 Standby Diesel Generators Model DSRIV16:
Starting Air Syste=
Check Valve [RDC 43(82)]
Dear Mr. Keppler:
Our final report dated Dece=ber 15, 1982, stated that =cdification'of the subject valves would be co=plete by July 1,1983.
The valves have been returned to Iransamerica DeLaval f or re=anuf acture cf the internal cc=penents.
DeLaval has reported to us that their subvendor, Willia = Powell Valve, cannot supply the necessary repair kit until Septe=ber 1983.
?.
It is now expected that =odification of these valves by DeLaval and reinstal-(
latien on site will be co=plete by Dece=ber 1983.
Please contact us if you have any questions.
Sincerely, Q
Tn. -Q~
Murray R. Edel:an Vice President Nuclear Group MF.I: pab cc:
M. M. L. Gildrer lac Site Of fice Director Of fice of Inspection and Enf orcement U.S. Nuclear Regulatory Co==issien Wa shingt on, D. C.
20555 U.S. Nuclear Regulatory Co==issien c/o Document Manage =ent Branch Washington, D.C.
20555 Eecords. Center, SEE-IN j
Institute cf Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 l
J
R THE CLEVELAND ELECTRIC llLUMIN ATING COMPANY Pp. ccx Sooo o cLtvEL Astr. onio mot o T ELEPHoNE 87111 677 9800 o ILLUMINAllNG Serving The Best 1.ocation in the Nation h
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ATTACHMENT 7 Jalwyn R. Davidson wcs e.:ssicENT SYSf f M ENGINEERING ANo CONSTRUCTION j
February 12, 1982 Mr. James G. Keppler Director, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Co= mission 799 Roosevelt Road
)
Glen Ellyn, Illinois 60137 RE:. Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Final Report on Location of l
Governor Lube Oil Cooler /
Standby Diesel Generator l
IRDC 45(82)]
["-
Dear Mr. Keppler:
to 10CFR50.55(e) concerning the L
This letter serves as a final'fe' port pursuant governor lube oil coolers on the standby diesel generators supplied by Trans-(,
Initial notification relative to this report was cade to~
Mr. John Streeter of your of fice by Mr. Ecanuel Riley of The Cleveland Electric a= erica Delaval.
14, 1982.
Illucinating Co=pany (CEI) on January includes a description of the de51ciency, an analysis of the This report saf ety i= plication, and the corrective action taken.
Description of Deficiency _
Transa= erica Delaval is supplying four (4) diesel generator units (Mod DSRV16) f or the Perry Nuclear Power PlantThe engine governor and governor lu standby power source.
d
=anuf actured by the Woodward Governor Company of Fort Collins, Colora o, and were installed and piped on the engine by Transamerica Delavel.
The potential def ect exists in the mounting location of the governor lube oil If the lube oil cooler is installed above (elevation) the oil level indicator of the governor, the possibility exists that air might become trapped cooler.
when the oil level in the governor is lov.
in the syste:
f I
innkyaisofSafetyImpittaticna
~
Gji,.Ifmairistrappedinthegovarnnr'soilsystem, engina starting, and thus Atandby electric power availability, may be affected.
Design Criterion 17 of
(',
Appendix A to 10CFR50 and Section 8.3.1.1.4 of the PNPP PSAR require an available standby power supply to provide for safe shutdown of. the reactor and to caintain the plant in a safe condition.
Corrective Action Initial notification of this potential defect was submitted to.CEI by Trans-america Delaval in a letter dated December 18, 1981.
Upon receipt of this notification, a visu.a1 inspection of all four (4) engines was conducted by Perry Project personnel along with a Transamerica Delaval technical repre-sentative.
This inspection verified that the lube oil cool-r was mounted on the turbocharger support bracket, above the governor oil level indicator.
Nonconformance Report PQS 0002 was then issued to control modification.
Information supplied by Transamerica Delaval states that moving the governor lube oil cooler to a location below the governor oil level indicator will eliminate this deficiency.
Transamerica Delaval has been notified of the existance of this deficiency at PNPP and will supply counting instructions and caterials (tubing).
The relocation of the cooler vill take place during engine asse=bly under the direction of a Transamerica Delaval service representative.
Co=pletion of this modification is presently scheduled for July 1,1982.
Sincerely,
(
/
n /
n Dalwy R. Davidson Vice President Syste= Engineering and Construction DRD:pab cc:
Mr. M. L. Gildner - NRC, Site Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
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Q Serving The Best Location in the Nation MJRRAY R. EDELMAN July 1, 1983 ATTACHMENT 8 VICE PatSloENT NJCM AR Mr. Ja=es G. Keppler Regional Ad=inistrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Co--4 ssion 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Location of Governor Lube Oil Cooler / Standby Diesel Generator
[RDC 45(82))
Dear Mr. Keppler:
Dur letter to you dated January 6,1983, indicated that corrective actions to resolve the relocation of the Governor Lube Oil Coolers would be ce=pleted by July 1983 for Unit 1 and September 1983 for Unit 2.
The governors have been returned to Transamerica DeLaval f or inspection and overhaul as detailed in our letter to you dated June 14, 1983 [RDC 59(82)).
Therefore, corrective action on the Lube 011 Coolers will not be co=plete until Nove=ber 1983 for
[
Vnit I and January 1984 for Unit 2.
Please call if there are any additional questions.
Sincere 0,,
'mt-Mu ray R. Edel an Vice President Nuclear Group MR2:pab
~
cc:
Mr. M. L. Gildner NRC Site Office Director Office of Inspection and Enforcenent U.S. Nuclear Regulatory Cc =ission Washington, D.C.
20555 U.S. Nuclear Regulatory Cc--4ssion c/o Document Manage =ent Eranch Wa shington, D.C.
20555 Records Center, SEE-IN Institute of Nuclear Power Operations
/
1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339
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Mr. James G. Keppler d '.
Regional Administrator, Region III C'.
Office of Inspection and Enforcement'.I U.S. Nuclear Regulatory Con. mission
- 'O 799 Roosevelt Road
, r..' '!.
. Glen Ellyn, Illinois 60137
- 1 Feirh Nuclear ?cver Plant RE:
Docket Nos. 50-440; 50-441
~ Final Report Concerning
' Deficient Code Data Reports
[KDC,47(62)]
Dear Mr. Keppler:
This letter serves as a final report pursuant to 10CFR50.55(e) and provides the status of cur evaluation of inadequate cede Data Reports submitted by varitas ranuf acturers for equipnent supplied to the Ferry Nuclear Power
?:oject.
Initial notification that these deficiencia.s were being evaluated by The Cleveland Electric Illucinating Cen;any (CEI) was' cade to your effice on February 23,19s2, by Mr. R. L. Vendrasek of CEI. Our interi: report on this subje:: vas submitted to your of fice on March 23, 1982, by CEI.
Description of reficiency 3
The icileving identified deficiencies reflect the inadequacies of the sube.itted Cide tata Reports:
- )
5ct all nozzles (and/or their' sizes) listed.
2) 1: proper and nissing ref erences for bolting cateria*l.
3)
Ir.c e: :e c t side of head to pressure (convex or concave) specified.
4)
Incorrect size for instrument taps specified.
These deficiencies represent discrepancies between the equip ent, designed in accc: dance with A.SME Code,Section III, and the Code Data Reports supplied by the nanufse:urer.
_ q
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(.
's Evaluation Results Upon identification of the problem, =eetin$s were held with the installing contractor, Perry Nuclear Fever Plant pers6:nel; and the National Board of Boiler and Pressure Vessel Inspectors and coccurrence was obtained by all parties on the requiranents of ASHI,.Section III (SCA 8300 and S400) for Code Data Report centent.
Eased on these agreed upon clarifications, a survey was conducted by the Ferry Project on a n'epresentative sample of ASMI Code Data R ep or.t s.
The cample included a Code Data Report for a typical piece of each type of equipscnt (e.g., tank, pump, cocpressors, etc.) f ron each vendor supplying Code equip ent.
This survey consisted of a ec=parison of the Code
. Data Report with the design drawing and a visual inspection of the equip =ent was then perfer:ed as appropriate to verify the results of each cc parison.
As a result of this survey, we have concluded dhat:
1.
Mest of the discrepancies identified were =inor in nature.
In all cases revieved, the inforcation necessary for =aking the Code Data Reports complete 'and a'ccurate was found to be available on site.
Information not listed on the data reports was centa;in'ed in the applicable design drawing and supporting docu:entation (i.e., Certified Material Test Report, etc.).
2.
All the Ccde Data Reports had originally been accepted by an Authorized Nuclear Inspection Agency.
The =ajority of discrepancies have been deter ined to be the result of variance in the interpretatica of code requitecents.
3.
The vas t naj ority of disc:epancies identified pertained to N-1, N-1A, and N-6 for:s submitted. f or pressure vessels and s:crage tanks.
Of these Code Data Report discrepancies, none invo'1ved any equiptent defects.
None of the Code Data Report corrections involved equipment changes.
4 The enly changes required were the correction of several Code sta R ep or t s.
No taterial er equisnent modifications were, required.
lased ec these conclusions, we feel that the ite:s were built correctly to the raquirements of ASMI,Section III, and the discrepancies noted on the Code sta ?.eports do not represent a significant deficiency, CErrective Action Those Code Data Reports which vere determined to be deficient vere returned,to the zanuf acturer fer correction and cost have been returned to PNPP.
The Naticnal 3 card of seiler and Pressure Vessel Inspectors v.as been asked to as sis t sene vendors in caking.the rc aining Code Data Report corrections.
The Fe:ry Nuclear Fevcr Project util also reco= end to the ASME and inspection
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Da:..in R. Davidson ATTACHMENT 10 5't*1V 1*.G". irk *.3 AND CoNSTRUCTrok
. :t sats :rt.:
Septenber 24, 1982 Mr. James G. Keppler Regional Administrator, Region III Office.of Inspection and Enforcement U.S. Nuclear Regulatory Co=cission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry nuclear' Power Plant Docket Nos, 50-440; 50-441 Standby Diesel Generator ASME Code Piping Welds [RDC 52(S2))
Dear Mr. Keppler:
This letter vill serve as the Final Report as recuired by 10CFR50.55(e) on the potential significs.nt deficiency concerning Trs.nsanetica Delaval Standby
{
Diesel Generator AS."E See:1on III, Class 3, piping.
This nat ter was firs t reported by Mr. E. Riley of The Cleveland Electric Illuminating Cenpany to
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Mr. J.1:eisler cf your of fice, on March 29, 1982.
An Interin Report was then subnitted on April 25, 1982.
This report contains a description of the deficiency, an analysis of safe ty i: plica tion, and ccrrective action.
DISCEIFTION OF DEFICIENCY Transacerica Delaval, Incorporated, is supplying four (4) diesel generator
-units, Model DSRV16, to be used as a s tandby power source for the Perry.
Nuclear Power Plant.
During a pre-ins talla tion inspection progran conducted by the ins talling cent.ractor, diesel generator jacke t water pipe 02.717.02DV/
75051 was found to have a fillet veld overlap which violated the surf ace condition of velds for ASME Section III Class 3 pipe.
In addition, lube oil pipe 02.717.0lTE/75051 had veld reinforcement which violated ASME Section III Class 3 requirements for veld reinforcement.
These nonconformances were docunented on site nonconformance report PO 39-0477.
Upon the detection of these two nonconfor=ing uelds, a sampling of all code piping velds was initiated.
This inspection consisted of apprcxi=a tely 20 pipes (100 velds) and approxinately 10 welds vere nonconforming.
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ANALYSIS OF SAFETY IMPLICATIONS
' Failure of any velds in this piping could result in diesel generator unavall-
- 2 i
ability. However, f ailure of these velds is unli':ely due to the lov operating pressures of the systens and the large design cargin used in systen design.
CORRECTIVE ACTION As a result of the identified deficiencies, an inspection of all ASME code pipe supplied by Delaval was initiated. At this time, veld inspection and any required repair and/or rework has been ec pleted for nearly all code piping on ene engine and approximately twenty-five percent for a second engine.
It is estinated that all corrective action vill nov be co:ple ted by April 1,1983.
If you have any cuestions, do not hesitate to contact us.
Sincerely, H
./Af Sh Dalvyn Davidson s.
Vice President Sys te: Engineering and Construction DRD: pab cc:
Mr. M. L. Gildner r
FEC site n'efce t
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Director Office cf Inspection and Enforcement U.S. Nuclear Regula tory Commission Washingten, D.C.
20555 U.S. Nuclear Eegul.itory Cc: issien c/o Document ':anzgenent Eranch Washington, D.C.
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!EJRRAY R. EDELMAN ATTACHMENT 11 vice ratsio NT wuctzAn July 1, 1983 Mr. Ja=es G. Keppler Regional Ad=inistrator, Region III Office of Inspection and Enforce =ent U.S. Nuclear Regulatory Co==1ssion 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Standby Diesel Generator ASME Code Piping Welds [RDC 52(82))
Dear Mr. Keppler:
Our letter to you dated April 1, 1983, indicated that repair vork on Code piping velds would be ce=pleted by July 1,1983.
All repairs to the Transa= erica DeLaval supplied skid =ounted piping have been co_pleted.
Tne docu=entation package used to track the repair vork is presently
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being reviewed.
Several discrepancies in the docu=entation package have been identified and =ust be corrected prio'r to final approval.
We erpect this action to be co=pleted by Dece=ber 1,1983.
Flea'se contact us if you have any cuestions.
Sincere'v 6
b,. LC_JA Murray R. Edel an Vice President Nuclear Group MEE:pcb cc:
M. M. L. Gildner NRC Site Office Director Office of Inspection and Enforce =ent U.S. Nuclear Regulatory Cc==ission Washington, D.C.
20555 U.S. Nuclear Regulatory Co==ission c/o Docurent Manage =ent 3 ranch Washington, D.C.
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Reccrds Center, SEE-lh Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339
pNE IHL ULtVELANU ELECTRIC ILLUMIN ATING COMPANY
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P.O. Box 5000 o CLEVELAND. ohio 4101 o TELEPHONE (216) L2M800 o 3 s5 PU LIC sbUA".E Serving The Best Location in the Nation (Dahyy'n P.. Davidson ATTACHMENT 12
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.sysTEu ENGIN!! RING AND CoNsTRUOTtoN June 28, 1982 Mr. Ja=es G. Keppler Regional Ad=inistrator, Region III Office of Inspection and Enforce =ent U.S. Nuclear Regulatory Co-ission 799 Ro6sevelt R.oad Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. ' -440; 50-441 Final Report on the Standby Diesel Generator Syste:
[RDC 57(82)]
Dear Mr. Keppler:
This letter serves as a final report pursuant to 10CFR50.55(e) concerning a potential def ect in the standby diesel generator syste= supplied by Transa=e' ica r
Delaval, Inc.
Initial notification that this proble vas being evaluated by The Cleveland Electric Illu=inating Company (CII) was =ade to Mr. P. Byron of
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your office on June 15, 1982, by Mr. R. L. Vondrasek of CII.
This'. report includes a description of the potential deficiency, an analysis of safety i= plication, and the planned corrective action.
Descrintion of Deficienev The Transanerica Delaval, Inc., letter dated May 13, 1982, to the Nuclear Regulatory Co==ission, identified a potential def ect in their diesel generator syste=.
Tn'is report was filed in accordance with 100FR, Part 21.
The Cleveland Ilectric Illu=inating Co=pany var first notified by Delaval of this def ect in z letter d'ated June 8, 1982.
Tne potential defect is related to the length of the capscrev which holds the starting air valve asse=bly in the cylinder head, If this capscrew botto=s in the tapped hole in the cylinder head during installation before the valve asse=bly is properly seated, the torque vrench reading would be isleading and the asse=bly could fail.
Tne starting' air valve.asse=bly was =anuf actured and installed in the cylinder head by Transa= erica Delaval.
Tne Perry Nuclear Power Plan has four diesel engines which include this valve asse=bly.
The total nu=ber. of valve asse=blies and capscrews in question is sixty-four (64) and one hundred twenty-eight (128) respectively r
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,. Annlyain of Sefaty I=olientions Failuna cf the starting air.velve assambly could result in a loss of starting dir pressure to the, engine cylinder and ce= pro =ise standby diesel start capability.
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((r, Planned Corrective Action Our review of the Delaval' Parts List indicates that the defective capscrew
'(P/N GB-032-114) was supplied to the Perry Nuclear Power Plant. The subject capscrews vill be inspected for proper length and replaced if defective.
Del,aval vill supply replacenent capscrews (P/N GB-032-113) and instructions to el1=inate this defect.
Cc=pletion of this corrective action is presently scheduled for April 1,1983.
l Sincerely,
/
d/ v4 r
Dalwyn R. Davidson Vice President Sy~s t e: Engineering and Construction DRD:pab cc:
Mr. M. L. Gildner NRC Site Office f
Director
' Office of Inspection and Enforce =ent U.S. Nuclear Regulatory Co-~4 ssion
'*achington, D.C.
20555 U.S. Nuclear Regulatory Cc--ission c/o Docunent Manage =ent Branch k'ashington, D.C.
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' MURRAY R. EDELMAN April 1, 1983 vict retsiorNT NUCM ARMr. James G. Keppler Regional Ad=inistrator, Region III Office of Inspection and Enforce =ent U.S. Nuclear Regulatory Co==ission 799 Roosevelt Road Glen Ellyn, 1111no.is 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Potential Defect in Starting Air Valve Assembly / Standby Diesel Generator Syste= [RDC 57(82)).
Dear Mr. Keppler:
This letter =odifies our final report dated June 28, 1982, concerning a potential defect related to the length of the capscrew which holds the starting air valve asse=bly in the cylinder head of the standby diesel generators. supplied by Transa= erica Delaval, Inc.
Initial notification that this proble= vas being evaluated by The Cleveland Electric Illu=inating Co=pany (CET) was =ade to Mr. F. Eyron of your of fice on June 15, 1982, by Mr. R. L. Vondrasek of CEI.
Co=pletion of the corrective action described in our final report and scheduled for April 1,1983, has been delayed because Delaval has sub=itted a revised f
inspection procedure which has in turn necessitated revision of GE's SP39 inspection procedure to properly reflect the revision =ade by Delaval.
This activity is currently in process and is expected to be co=pleted in a ti=e f ra=e that will allow rework to begin later this =onth.
Some additional de' lays are anticipated due to installation of large bore piping above the cylinders by our piping contractor.
In light of the above, se now anticipate ce=pletion of all necessary corrective action.by August 1, 1983, for Unit I and Dece=ber 1, 1983, for Unit 2.
Please call if there are addi,tional questions.
Sincerely, 7//.
Murray R. Edel=an Vice President Nuclear Group FFrI:pab l
cc:
Mr. M. L. G11dner NRC Site Office 9
Director Of fice of Inspection and Enforce =ent U.S. Nuclear Regulatory Co==ission Washingt on, D.C.
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' A-Serving The Best Location in the Nation D lwyn R.Davidson ATTACHMENT 14 vsCE PRE $r0ENT SYStf u E NGtNEERING AND ccNSTRUcis0N August 26, 1982 Mr. James G. Keppler Regional Administrator, Region III.
Office of Inspection and Enf orcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docke t Nos. 50-440; 50-441 Final Report on the Governor Drive Coupling [RDC 59(82)]
Dear Mr. Keppler:
This letter serves as a final report as required by 10CFR50.55(e) concerning a potential significant deficiency in the material used in the governor drive coupling for the Transamerica Delaval diesel generators.
It was reported by Mr. R. L. Vondrasek of The Cleveland Electric Illuminating Company (CEI) on July 30, 1982, in a telephone conversation with Mr. Paul Pelke of your office.
The potential deficiency concerns the standby diesel generators, model DSRV 16 supplied by Transamerica Delaval, Incorporated.
Transamerica Delaval notified the NRC of this potential deficiency under 10CFR21 in a letter dated June 23, 1982 CEI received this informa tion in a letter da ted August 18, 1982 This repo rt contains a description of the deficiency, an analysis of safety impli-cation, and a corrective action planned.
Description of Deficiency Transamerica Delaval is supplying four (4) diesal generator units (model DSRV 16) for the Perry Nuclear Power Plant (PNPP) that vill be used as a s tandby power source for the PNPP.
The potential deficiency, as described by Transamerica Delaval, exists in the governor drive coupling.
The failure could result in engine nonavailability.
The potential defect is related to the material used in the couplings. The material, an isoprene, was designed for atmospheric use and is not suitable for use in high-temperature, oil atmosph'ere encountered in the engines' gear case.
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{a Transamerica Delaval has reported that the rubber used in the coupling drive element deteriorates rapidly and ultimately fails.
While the coupling is
" fail safe" and will mechanically lock-up when the element fails, sufficient f requency instability could be induced that would result in the engines tripping off-line.
Corrective Action The corrective action will be to replace the coupling's flexible element and, if necessary, replace the governor drive coupling.
This will be accomplished in accordance with Transamerica Del'aval's recommended corrective action (letter dated 8-18-82).
The rework will take place during the normal installation program under the direction of a Delaval service representative. The work will be completed by June 15, 1983.
Sincerely, M
Dalwyn. Davidson Vice President System Engineering and Cons truction DRD:pab
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NRC Site Office cc:
Mr. M. L. Gildner Director Office of Inspection and Enforcement U.S. Nuclear Regula tory Cc= mission Washington, D.C.
20555 U.S. Nuclear Regula tory Commission c/o Document Management Branch Washington, D.C.
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ATTACHMENT 15 Dece.d e m.,2, 1982 MJRMY R. EDELMAN.
VICE PRESIDENT NUCLEAR Hr. Ja: Des Keppler Regional Administrator, EeS on III i
Office of Inspection and Enforcement U. S. Nuclear Regulatory Co.u ission 799 Roosevelt Road Glen Ellyn, Illinois 60137 EE:
Ferry Nuclear Fower Plant Standby Diesel Ge.nerators DSEV16.
Potential Defect Concerning IEEE 2E3 1
Failure in Certain Class IE Circuits
.(EDC63(82))
i - De r Mr. Keppler:
This letter serves as an Interim Report pursuant to 10CFE%.55(e) cencerninE a pc. ten"a1 defect in the standby diesel generator system supplied by Transamerica DeLaval, Inc. (TDI).
Initial notification that this problem was being evaluatec by The Cleveland Electric Illu.inating Ccepany (CEI) was made to your office on Ecre:ber 22, 19E2 by Mr. E. Riley CEI.
DESCRIPTIOK OF POTENTIAL DEFIC 1ENCY 4
s Transamerica DeLaval, Inc. notified CEI that cc: ercial grade w?.re had been used as Clans, 1E cable in certain er.gine and panel circuits.
This cable has recently failed the IEEE f 353 Insulation Flane Test.
An initial review cf the circuits in question indicates that the circuits identified by Transamerica DeLaval =sy perform safety-related fur.ctions.
Further,cenversation with DeLaval will be required to determine the consequences if these circuits fail.
The Final-Repcrt cencerning this potential proble.m will be submitted by March 30,19E3.
i Very truly yours, N
WM Murray n. m.celman Vice President l
Kuclear Group IEE:d:
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Mr. M. L. Gildner GhC Site Office
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FAJRRAY R. EDELMAN ATTACHMENT 16 septe=ber 27, 1983 v,cr mesmtur NucMAR Mr. Ja:es G. Keppler Regional Administrator,' Region III Office of Inspe: tion and Enforcement U.S. Nuclear Regulatory Cc=cission 799 Rocsevelt Road Glen.Ellyn, Illinois 60137 RE:
Perry Nucicar Power Plant Docket Nos. 50-440; 50-441 Standby Diesel Generators DSRV 16 Potential Defect Concerning IEEE 383 Failure in Certain Class 1E Circuits [RDC 63(82)]
Dear Mr. Keppler:
This letter concerns our interim report pursuant to 10CTR50.55(e) concerning the potential defect associated with the f ailure to =eet IEEE 383 insulation fla=e test by certain Class 1E engine and panel circuit wiring in the Standby Diesel Generaters, Model DSRV 16 supplied by Transamerica Delaval, Inc.
previously sub=itted correspondence on this subject was transmitted March 30, 1983, and Dece ber 22, 1982.
Cur final report is nov scheduled to be sube.itted by Dece:ber 30, 1983.
Additional time is needed to conplete cur review cf the vendor's information pertaining to the consequences associated with the postulated f ailure of the affected circui:s.
Picase call if you have any questiens.
Sincerely, W
MA Murray R.
delman Vice President Nuclear Group MRE:pab cc:
Mr. M. L. Gildner Nhc Site Office Director l
Cffice of Inspection and Enforcer,ent 1
U.S. Nuclear Regulatory Cenmission
- 'ashington, D.C.
20555 U.S. Nuclear Eegulatory Cecmission c/o Document Manage =ent Branch
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20555 Records Center, SEE-!N Institute of Nuclear Pcwer Operations 1100 circle 75 Parkway, Suite 1500 At:anta, Georgia 30339 h.
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MVP.%Y R. EDELMAN ATTACHMENT 17 vict misio:NT July 1, 1983 NbolAR Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Canmission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Piping Supports Supplied by
- Transamerica Delaval, Inc.
[RDC 67(83)]
Dear Mr. Keppler:
Ihis letter serves as the final report pursuant to 10CFR50.55(e) concerning ASME Code Section III, Class 3, piping supports supplied to the Perry Nuclear Power Plant by Transamerica Delaval, Inc.
Mr. P. R. Pelke of your office was first notified on February 23, 1983, by Mr. E. Riley of The Cleveland Electric
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Illu=inating Company (CEI) that this proble= vas being evaluated.
Our previous reports on this subject were submitted March 25, 1983, and April 29, 1983.
This report contains a description of the deficiency, an ana'.ysis of safety implications and the corrective action taken.
Description of Deficiency Specification 562-4549-00, Section 2:05 Ite: 3a and section 2:16 Item 1, require that most piping components are to be built to the ASME Code Section III, Class 3.
Transamerica Delaval, contracted under specification 562-4549-00, supplied skid mounted piping supports without material certification and identification as outlined in ASMI NF-2130 and NF-2150.
Analysis of Safety Implications Engineering analysis has determined that although the supports supplied by DeLaval did not meet the material traceability requirements specified in ASMI NF-2130 and NF-2150, there is little probability a safety hazard exists because the supports were seismically qualified.
Houever, in order to satisfy the subject ASME requirements, corrective action as detailed below has been taken.
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.n Correctiva Action fi DeLaval has completed reanalysis of the skid piping supports and has supplied revised drawings vEich detail the ASME Section III Subsection NF Support
, Boundaries and the components which must be modified or replaced to meet Subsection NT criteria.
The drawings have been issued to our installing contractor (General Electric) and Code materials are being procured by DeLaval, General Electric, and CEI.
These materials vill be supplied to General Electric, who vill upgrade the supports on site.
We anticipate co=pletion of these actions by December 1983.
Please contact us if you have any questions or comments.
Sincerely, 7 77-
&~ fu Murray R. Edelman Vice President Nuclear Group cc:
Mr. M. L. Gildner NRC Site Office Director
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Office of Inspectier and E'nforcement
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U.S. Nuclear Regulat ry Co--ission Washington, D.C.
20555 U.S. Nuclear Regulatory Ce=tission c/o Docunent Management 3 ranch Washington, D.C.
20555 Records Center, SEE-IN Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 I
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ATTACilMENT 18 MJMAY R. EDELMAN
,a VICL P*ttlDENT hucuAn August 30,,,1983 2
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Regional Administrator, Region III Office of Inspection and Enforce:ent y.
U.S. Nuclear Regulatory Co mission 799 Roosevelt Road Glen Ellyn, Illinois 60137 k
RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Design of the Diesel Centrator Exhaust Piping [RDC 7'8(83))
Dear Mr. Keppler This letter serves as the interim report pursuant to 10CFR50.55(e) on the deficiencies coccerning exhaust line back pressures exceeding manufacturer's ffr recc:=endations on the Standby Diesel Generators and the Diesel Generators for (2f#
the High Pressure Core Spray System (HPCS).
Mr. P. R. Pelke of your office was notified on August 5, 1983, by Mr. C. M. Shuster of The cleveland Electric Illucinating Co:pany that this problem was being evaluated.
On July 27, 1983, Gilbert Annociates, Inc. (CAI), the Architect / Engineer for PNPP, notified the Nuclear Regulatory Cc= mission, under 10CFR21, of a deficiency involving the design of diesel generator exhaust piping.
This report contains a description of the deficiencies and corrective action.
Description of Deficiencies The design of the exhnust piping for the Standby Diesel Cenerators is such that exhaust flows greater than 75% of rated flow could result in engine stalling, thereby preventing the diesel generators from nupplying emergency pover.
The design of the exhnust piping for the High Pressure Core Spray (P.PCS) diesel Eenerators is such that the backpressure at rated flov exceeds canu-facturer's reconnendations.
Existence of excessive backpressure could cause engine stalling at rated Icad and consequent failure of the EPCS system to perform.
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' Planned Courso of Action
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Wa prostutly enticipcto, that additionni dasign information needed froa Trcus-tC ascrica Delaval for completion of our evaluation for significance vill be
'submitt.ed in October.
Further course of action vill be determined at that This condit' on is being controlled on' site'through a PNPP nonconfoimance time.
i report, WR TAS' 54.
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Our n, ext report 'on 'this. subject vill be issued by Decedber 15, 1983.
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Please call if "there are any ' additional questions.
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nis letter sedes as an interi= report pursuant to 10CTRSO.55(c) concerning the use of non-Cissa 1E power to operate control devices and use of n:n-Cir.ss 1E control components in the circui'ts which provide control signals to the diesel ' generator. building ventilation system.
Mr. P. R. Pelke of your office was first notified on August 16,1983,, by Mr. E. Riley of na Cleveland Electric.
111t=:1 ating Conpany that this problem vas being ev,aluated.
This report contalis a description of the de.ficiency and the planned course of action for ee:pletion of our evaluation for significance.
Descriptic'n of Deficiency Relays R1A and RIAA associated with the standby diesel generators are used to centrol the safety-related ventilation systems equipeent in the diesel generator
' building.
Transa= erica Delaval supplied the. standby diesel generator syste=.
The Transanerica Delaval schematic 09-%$00-15051, sheet 5. Revision D, indicates that these relays are operatid by a non-Class 1E power supply.
- In 4ddition, two control cenponents, an auxiliary latch relay R1 and a time delay relay TD-3, contr-1 the diesel generator building ventilation systems through the Rik and RIAA relsys.
The referenced schenatic designates.these co=ponents as non-Class 1E devices.
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73 presantly cnticipate,that cdditional dasign informntion needzd froa Trans-Q.-
, a;:erdca Delaval for co:spletion of our evaluation for significance vill be submitted in Octob,er.
Further course of action vill be determined at that, time.
This condition is being controlled on site through a PNPP nonconfor=ance
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report, NR TA S' 54.. '
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Cur next report on 'this subject vill be issued by Decedber 15, 1983.
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1 Sincerely.
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Hurr'ay R. Edelman
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Vice Presideut I
Nuclear Group MPI:p'ab
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Er M. L. Gildner NRC Site Office Director.
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Cf fice of Inspection and Enforce: tent U.S. Nuclear Regulatory Co==ission Washingtog D.C.
20555 (i.~.
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F U.S. Suc1 car Regulatory Ce==ission
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c/o Docu=ent Management Branch
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20555 " a T '--- Eecords Center, SEE-IN institute of Nuclear Power Operations
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1100 circle 75 Parkvay, suite 1500 Atl,anta, Georgia 30339 e
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j NUCLEAR REGULATORY COMMISSION RECEIVED t:AsocTow. o. c. 2cssa g
.l SEP 10 ;g;3 f
M. R. FortgAg y
ATTAcnMr>:T 20 i
SEP 141983
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Docket Nos.:
50-440 and 50-441 2
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Mr. MJrray R. Edelman I
Vice President - Nuclear Group f
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The Cleveland Electric Illuminating Company i
P. O. Box 5000 C1eveland, Ohio 44101
)/'
Dear Mr. Edelman:
of the Diesel Generator Tests for Perry Nuclear Acceptability (Units 1 and 2)
Subject:
i Power Plant 1
Your letter dated June 15, 1983 clarified your comitment to perform a total of 20 start-and-load tests in addition to the plant preoperational test pro-This additional testing would result in a total of 89 tests for the gram.
diesel generators (divided 45 tests on one generator and 44 tests on the other standby diesel generator).
You advised that the 20 additional start-and-load tests will be conducted in accordance with Regulatory Guide 1.9 and IEEE Standard 387-1977, Section 6.3.2, with one exception.
Since a single step load of 50% of the diesel generator nameplate continuous rating is not avail-able in the plant, you plan to load the generator with the available bus load once it has attained the necessary speed and voltage.
The bus will then be synchronized with offsite power and loaded as quickly as possible to 50% of rating.
The preoperational reliability testing will be performed in accordance with Regulatory Guide 1.108, Position C.2 as clarified in Table 1.8 of the Perry FSAR.
The staff has reviewed your clarification for the diesel generator test and finds them to be acceptable. We plan to incorporate this finding in the next SER supplement, under Section 8.3.1, scheduled to be issued in November 1983.
In addition, the NRC Power Systems Branch staff reviewer (S. C. Rhow) intends to conduct an onsite audit of the plant electrical power systems during the week of September 26, 1983.
Specific dates, times, and an agenda for the areas to be audited will be announced separately.
RECEIVED SEP 191983 LICENSING
e Mr. Murray R. Edelaan,.
r:
If you have any questions, please direct them to the Perry project manager, John J. Stefano.
Sincer ly, J
B. J Y ungblo
, Chief Lic ns ng Bra h No. 1 Div sion of Licensing cc:
See next page op 1
g Mr. Murrey 2.. Edelean "ico President, Nuclear Grcuo she* Cleveland Electric 111uminating Company D. O. Box 5000 g
l Cleveland, Ohio 44101 i
cc:
Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Washington, D. C.
20006 Donald H. Hauser, Esq.
The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Conmission Partly at Center Road
- Perry, Chio 44081 U. S. Nuclear Regulatory Commission Mr. James G. Keppler, Regional AdT.inistrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois. 60137 Donald T. Ezzone, Esq.
Assistant Prosecuting Attorney
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105 Main Street take County Administration Center Painesville, Ohio 44077 Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Menttr Ohio 44060 Terry J. Lodge, Esq.
McCormick, Pomm.eranz & Lodge 824 National Bank Building Toledo, Ohio 43604 John G. Cardinal, Esq.
Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047 8
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