ML20079P610

Motion to Admit Supplemental Diesel Generator Contentions Re Reliability & Adequacy.Unexecuted Affidavits of SG Christensen & Gd Eley Encl

ML20079P610
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/27/1984
From:	Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079P612	List: ML20079P610 ML20079P615
References
ISSUANCE-OL, NUDOCS 8401310284
Download: ML20079P610 (70)

Text

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.o DOCKETED USNRC g 1/27/84 UNITED STATES OF AMERICA 84 34!30 N0 50 NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY i Docket No. 50-322-OL

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(Shoreham Nuclear Power Station, )

Unit 1) )

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SUFFOLK COUNTY'S MOTIOri TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS I. INTRODUCTION This Motion and the Addendum to this Motion (attached hereto and forming a part hereof) are filed pursuant to this Board's

" Order Confirming Schedule for Supplemental Diesel Generator Contentions" dated January 4, 1984. They result from a chain of events regarding developing concern with the adequacy and reli-ability of the emergency diesel generators ("EDGs") at Shoreham.

On May 2, 1983, Suffolk County moved for leave to file a new contention that, based upon enumerated data, LILCO had " failed to ensure rapid starting and reliable operation" of the EDGs. By a

" Memorandum and Order Ruling on Suffolk County's Motion to Admit -

New Contention," LBP-83-30, 17 NRC 1132 (June 22, 1983), this Board admitted the County's EDG contention, limited to the issues of the cracking of cylinder heads and excessive vibration. The cylinder bead issue was recognized as a potential bar td"a' low-power operating license for Shoreham; the vibration issue was i

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. 7 characterized as "long-term" and of no significance to low-power testing.1! 17 NRC at 1155, 1150.

The parties were preparing for the hearing on the cracked cylinder head issue when, on August 12, 1983, the crankshaft of

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EDG 102 broke in half during testing after installation of replacement cylinder heads. At LILCO's request and with the l'

concurrence of the County and the Staff, this Board indefinitely deferred litigation of the cracked cylinder head issue. See

" Memorandum and Order Deferring Filing of Testimony and Com-mencement of Hearing on Diesel Generators," August 16, 1983;

" Memorandum and Order Cranting Requests of Parties to Continue Deferral of Litigation of-Diesel Generator Contention," August 29,

, 1983.

LILCO commenced an effort to determine the cause(s) of the o

- broken crankshaft. In the course of that effort the three EDGs were disassembled and inspected, revealing numerous serious problems not disclosed by prequalification tests. These problems include:

e Cracks in crankshafts of all EDGs Cracked pistons (23 of 24 pistons in all EDGs)

Low mcgger reading on rotor Damaged connecting rod bearings s

Cracked bed plates Jacket water pump shaft wear Fretting of main journal bearing surfaces Pitting of lobes on camshaft Damage to governor Gouged piston rings Cracked f,1ywheel-bolts Pitting and grooving of cylinder liners Fretting of jacket water pump drive gears Cracked and fractured cylinder head nuts Missing dowel pins on lube oil drive support Broken bolts at turbo exhaust inlet adaption 1/ See discussion infra at 5-6.

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s See LILCO's Diesel Generator Status Reports dated August 25,

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September 21, October 7, October 20, November 3, and November 17, 1983. Although LILCO has not issued any Status Reports since  ;

November 17, 1983, new problems continue to arise with the EDGs.

. For example, on December 10, 1983, the failure of rocker arm I

hold-down bolts during testing of EDG 101 caused damage to the cylinder sub-assembly, as reported by LILCO during the January 3, 1984 telephone conference among this Board and the parties.

l The multiplicity of problems and deficiencies with the EDGs made known to Suffolk County have been reviewed and analyzed by the County's expert consultants. Although the County has not received all of the reports on EDG problems promised by LILCO, !

its consultants have sufficient material to reach the conclusions set forth in the proposed supplemental contentions attached as Annex A.

Suffolk County hereby moves that the supplemental contentions concerning the EDGs be admitted.

II. THE SUPPLEMENTAL CONTENTIONS The many defects discovered in the EDGs clearly point to an overall problem with the EDGs. Diesel engines are complex machines, comprised of many parts and components in dynamic inter-relationship. The concept that if one part is defective in design or manufacture, it can simply be replaced by a redesigned 2/ See Suffolk County's Answer and Opposition to LILCO's Motion to Set Schedule, December 23, 1983, at 7-11. Several of the reports listed in that Answer have since been received and reviewed.

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or remanufactured part, without regard to the effects upon other engine componer{ts and the operation of the entire diesel engine, is a dangerous fallacy. Suffolk County's supplemental EDG contentions-(Annex A)' address the design and manufacture of the entire EDG. ThS cententions conclude that the EDGs at Shoreham cannot meet regulatory-requirements for reliable operatinn and must be replaced.

+ The County's supplemental EDG contentions are, in summary:

1. The ED7s cannot adequately perform their required functions'becauseNheyareundersizedandover-rated. The EDGs

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are essentially the 'same design as engines developed in the 1950's, but their horsepower has been more than doubled. The

,s original crankshafts, pistons and cylinder heads all have suffered cracking,;which is evidence that the EDGs are over-rated. Re-t placement comfonents have not solved the basic problem that the

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EDGs are uadersized, iThe replacement crankshafts are of marginal dei gn ' at! ' full power operation, are inadequate for over-load-operation, and.will cause excessive wear and loosening of the main bearing ind crankshaft misalignment. The replacement pistons are also of inadequate design..to withstand operating conditions and are unproven. The replacement cylinder heads are of inadequate desigry and manuf acture to- satisf actorily withstand thermal and i

l mechanical loads. The inter-relatio'nship of these major com-l ponents and.others may exacerbate their inherent individual

. weaknesses.

l 2 .- Numerous EDG components are improperly designed. A, number of;these design defects have not been rectified. The 4

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pattern of design deficiencies in diesel engines manufactured by Transamerica Delaval, Inc. ("TDI") demonstrates that there can be no reasonable assurance that there are not additional design deficiencies which will result in failures of other parts or components of the EDGs.

3. The EDGs are not satisfactorily manufactured. The pattern of manufacturing defects in the EDGs and in other diesel engines manufactured by TDI demonstrates that there can be no reasonable assurance that there are not additional manufacturing defects which will result in failures of other parts or components of the EDGs.

4. The EDGs and their components, including the replacement crankshafts, pistons and cylinder heads, were not manufactured under an effective Appendix B quality assurance program. Accord-ingly, there can be no adequate confidence that the EDGs and those components will operate reliably.

The County's supplemental contentions subsume the admitted EDG issues -- the cracking of cylinder heads,and excessive vibra-tion -- as well as the general contention that as a result of each of those issues the EDGs will not operate reliably. The cylinder head cracking issue is a part of the proposed supplemental con-l tentions and is particularly discussed in Contention I. The .

County believes that not only are the cylinder heads likely to crack, as in the past, but also that their inadequate design and poor quality makes them unable to-withstand operating conditions.

The cylinder head problems are indications that the EDGs are undersized and over-rated.

O The excessive vibration issue is also a part of the proposed

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contentions. Excessive vibration experienced by the EDGs is an indication of the inadequate design and unsatisfactory manufacture of the EDGs, which result in part from an ineffective quality assurance program. In addition, excessive vibration and differ-ences in the amplitude of vibration among the three EDGs are indications that the EDGs are undersized to perform their required function. For these reasons Suffolk County does not believe that it is appropriate to treat excessive vibration as a separate, "long-term" issue having no significance to low-power operation.

4 'Ihe bases for the supplemental EDG contentions are detailed by reference to particular LILCO reports, NRC Staff inspection reports and other Staff documents, reports by TDI pursuant to 10 C.F.R. Part 21, reports issued under 10 C.F.R. @ 50.55(e), docu-ments obtained from owners or operators of TDI' diesel engines, and other relevant material. In addition, the bases for Contention I

are' explained in affidavits of the County's expert consultants on diesel engines attached to the contentions (Attachments 1 and 2 to Annex A). The list of deficiencies and defects in TDI diesels supporting the supplemental contentions will be enlarged as addi-tional information is developed through discovery and the ongoing l investigations.

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Suffolk County's supplemental contentions are far more detailed and particularized than the late-filed TDI diesel contention recently admitted in Cleveland Electric Illuminating l

Company (Perry Nuclear Power Plant, Units 1 and 2). There, by a

" Memorandum and Order (New Contention on Diesel Generators)" dated I

December 23, 1983 (the " Perry Board Order," a copy of which is

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attached as Annex B),- the Board framed and admitted a contention that Applicant has not demonstrated that it can reliably generate emergency on-site power by relying on four Transamerica Delaval diesel generators, two for each '

of.its Perry units. ,

The Board found that this contention was supported with sufficient specificity by the following bases:

1. The broken and cracked crankshafts in TDI diesels at Shoreham, which involved improper crankshaft design.

2. Eleven specified deficiencies in the Perry TDI diesels (some of which may be related to design problems), which had been referred to as " harbingers of troubles to come." Id. at 3.

3. NRC Staff concerns about TDI diesel engines and problems with quality assurance at TDI, evidenced in part by Board Notifi-cation 83-160 (October 21, 1983).

These same bases are, of course, a portion of the much more comprehensive and detailed bases supporting the County's supple-mental EDG contentions.

III. STANDARDS FOR ADMITTING THE SUPPLEMENTAL EDG CONTENTIONS Based ,upon this Board's analysis of the legal standards which must be met for the admission of late-filed contentions in LBP-83-30, Suffolk County believes that the factors in 10 C.F.R.

Section 2.714(a)(1) must be applied, but that the criteria for reopening the record are not applicable. With respect to the latter issue, the controlling fact is that the record has already

been reopened to admit the existing EDG contention. In general Q

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terms, that contention challenges the reliability and capability of the EDGs at Shoreham. That this Board, given the evidence then before it, limited the contention to the issues of cylinder head cracking and excessive vibration, does not alter the fact that the record is and remains open concerning the reliability and capability of the EDGs.

This Board presented guidance on this matter in LBP-83-30 in its discussion of the common practice of segmenting major portions of a case for litigation. See 17 NRC at 1136-38. There this Board noted that the reopening criteria apply where a party seeks to provide or other-wise adduce new evidence for-the purpose .

of supplementing the record on a conten-tion on which the evidentiary hearing has been completed .- . .. . This is so even if other unrelated contentions remain to be litigated.

i 17 NRC at 1137 (emphasis added). Here the evidentiary hearing on the County's EDG contention has not even begun. Moreover, the County's proposed supplemental EDG contentions are not merely related to the existing EDG contention, but are a part of the same i

subject matter. The supplemental contentions would clearly " fit under . . . a segment which is still pending" (17 NRC at 1138),

and in fact are an expansion, elaboration, and further particular-ization of the admitted EDG contention resulting^from new evidence.

In any case, we note this Board's comment that

[I]n our view, the additional test of the criteria for reopening the record adds little, if anything, of practical import

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to the application of the factors for a

, late-filed contention . . . .

17 NRC at 1143.

The factors to be balanced pursuant to Section 2.714(a)(1) in determining whether to admit the County's supplemental EDG con-tentions are:

1. Good cause, if any, for failure to file on time. There; can be little doubt that Suffolk County's supplemental EDG con-tentions have been filed in a timely manner. The crankshaft on EDG 102 broke in half on August 12, 1983. On August 22, 1983 the~

County filed with this Board Suffolk County's Notice of Potential Motion to Admit New Contention on Diesel Generators, which sug-gested that the County might file for admission of additional EDG contentions, and that the timeliness of such supplemental conten-tions should logically be judged from after LILCO made known its conclusions regarding the crankshaft failure, rather than the date the crankshaft broke. The Notice invited any party who disagreed with this position to present its views; neither LILCO nor the Staff disagreed. In fact, LILCO stated that it would not "be productive to conduct any litigation on diesel generator issues until issuance of FAA's failure analysis report." LILCO's Status Report on Diesel Generator Crankshaft Matters, August 25, 19P1, at 6 (emphasis added).

When LILCO and its chief consultant, Failure Analysis Associates ("FaAA"), began to disassemble and inspect the three EDGs, a large number of new problems were disclosed. See supra at 2-3. LILCO reported that FaAA would issue "a comprehensive report

. on the disassembly" of the EDGs. LILCO's Diesel Generator Status Report.("DGSR"), September 21, 1983, at 7. Accordingly, it was clear to all parties that the FaAA report would go well beyond the crankshaft failures. Suffolk County concurred with LILCO's deferral of EDG litigation until after issuance of the compre-hensive FaAA report, since only after that time would the problems disclosed by the FaAA inspections be revealed and analyzed.

Subsequently LILCO determined that FaAA's " comprehensive report" would not be issued; instead a series of FaAA reports covering specific matters were to be given. DGSR, October 20, 1983. The County has not received all of the promised reports.

See Suffolk County's Answer and Opposition to LILCO's Motion to Set Schedule, December 23, 1983, at 8-10.

The County received on November 3, 1983, FaAA's EDG Crank-shaft Failure Investigation report, dated October 31, 1983.

Expert consultants promptly began their review and analysis of that report, and requests were made to LILCO for materials per-tinent to the crankshaft issue.3/ The County did not file a contention confined solely to the crankshaft failure, because the developing information regarding the TDI diesels called for an analysis of the inter-relationship of all parts of the EDGs and pointed towards the conclusions stated in the supplemental EDG contentions regarding the entire EDG. It was not until LILCO's DGSR of November 17, 1983, for example, that the County learned of 3/ For example, bhletterofNovember10, 1983, the County requested a copy of the " test book" referred to en page 4-2 of the FaAA report as "available upon request." LILCO did not mail the test book to the County until Tanuary 12, 1984.

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the extensive cracking of pistons in the EDGs. The County o

promptly requested information from LILCO regarding the pistons to enable consultants to conduct some analysis of the problem. While FaAA has not yet issued a report on the cause(s) of the piston failures or the adequacy of the replacement pistons, County experts recently were able to reach the conclusions of proposed Contention I -- that the EDGs are undersized and over-rated to perform their required functions -- based partly upon their analysis of the piston failures, including data received from LILCO in mid-December.

A good deal of the material supporting proposed Contentions II, III and IV regards events which occurred before the crankshaft failures. The significance of these events, however, only became clear recently, after the crankshaft failures and the disclosure of the multiplicity of EDG problems during the disassembly and physical inspections through November 1983. These recent events and discoveries give new meaning to the older events, which now form important cumulative evidence supporting the County's supple-mental EDG contentions. In the context of the supplemental contentions, the prior events are relevant and timely. As the Board stated in the Perry case:

.The fact that other parts of the jigsaw puzzle of inadequate quality assurance were previously available does not de-tract from the significance of this new information.

Perry Board Order at 6. It should be recalled that while the NRC Staff opposed the admission of the County's EDG contention in the spring of 1983, it now clearly regards the TDI diesels as having

6 significant problems to which events prior to August 1983 are 4

viewed as directly relevant.4/ In fact, the Staff supported the admission of the TDI diesel contention in Perry.

In summary, the' County did not have sufficient information to reach supportable conclusions set forth in the supplemental EDG

-contentions until mid-December 1983. Even then, the County opposed a schedule requiring supplemental contentions to be filed, for the reasons set forth in Suffolk County's Answer and Opposi-tion to LILCO's Motion to Set Schedule, dated December 23, 1983.

This Board's order during the conference call of the parties on January 3, 1984, gave the County until January 27 to file its supplemental EDG contentions.

For all the foregoing reasons, we believe it is clear that the County's supplemental EDG contentions were timely filed and the first factor of Section 2.714(a)(1) weighs in the County's favor.

2 and 4. The availability of other means whereby the peti-tioner's interest will be protected, and the extent to which the petitioner's interest will be represented by existing parties.

There are no other means available for Suffolk County to protect I

its interest in the reliability of the EDGs and the safety of the l

Shoreham plant, nor can the County's interests be represented by i

! cther parties. Clearly, the proceeding before this Board, in 4/ Board Notification 83-160 refers to the " abnormally high" number of problems experienced by TDI diesels and includes i

attachments describing some events prior to the crankshaft

' failures. The Staff's interest and concern with these prior problems is also evidenced in its draft "NRR' Program Plan" to investigate TDI EDGs, sent to the County on December 20, 1983, which tabulates TDI. diesel problems for a three year period.

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which the County has so actively participated and before which there are pending the limited EDG contentions of the County pre-viously admitted, is the proper and appropriate forum in which the County's concerns may be addressed.

The County, this Board and the other parties are aware that the NRC Staff is conducting its own investigation of the EDGs.

See draft NRR Program Plan for investigation of TDI diesels, furnished under cover of the Staff's letter dated December 20, 1983 (the "NRR Plan"). However, the Staff cannot adequately represent the County's interest and concerns. The Staff has apparently reached no conclusions regarding the EDGs, while the County has come to the conclusions set forth in the supplemental EDG contentions. It is possible that ultimately the Staff's positions may differ in detail, if not in substance, from those of Suffolk County. Under these circumstances, the role of the Staff does not substitute for direct participation by the County. See Washington Public Power Supply System, ALAB-747, 18 NRC (November 15, 1983), slip op. at 13-14, quoted and relied upon in the Perry Board Order at 6; Cincinnati Gas and Electric Company (William H. Zimmer Nuclear Station), LBP-79-22, 10 NRC 213, 215 (1979). Accordingly, the second and fourth factors weigh in the County's favor.

, 3. The extent to which the petitioner's participation may reasonably be expected to assist in developing a sound record.

The County's supplemental EDG contentions are of great signi-ficance and bear heavily upon the possible outcome of the Shoreham licensing proceedings. These contentions conclude that the EDGs

e a cannot be repaired to operate properly and reliably. Because the EDGs are undersized and over-rated to adequately perform their functions, because the quantity and severity of design and manu-facturing defects show there can be no reasonable assurance that the EDGs will operate reliably, and because the fact that the EDGs and their major components were not designed and manufactured under an effective quality assurance program indicates there can be no confidence in EDG operation, the EDGs must be replaced by ones not manufactured by TDI.

Suffolk County has retained expert consultants on diesel engine matters, who have already devoted considerable time and effort towards analyzing EDG. problems. They include Professor Stanley G. Christensen of the United States Merchant Marine Aca-demy, an internationally recognized expert, author and. teacher concerning diesel engine design, manufacture, operation and repair. Professor Christensen's credentials are detailed in Exhibit A to his affidavit, Attachment 1 to Annex A. The County has also retained Ocean Fleets Consultancy Services, with offices in New York and New Jersey, for diesel engine expertise. Ocean Fleets, a division of a large European-based shipping conglom-erate, has three_ experts who will work on Shoreham EDG matters.

The resumes of Mr. Thomas A. Moore and Mr. Aneesh Bakshi are attached as Annex C. The credentials of Mr. George Dennis Eley, ,

who has already performed significant work on the Shoreham EDG problems, are attached as Exhibit A to his affidavit, Attachment 2 to Annex A. Additional technical expertise will be available from Ocean Fleet's offices in the United Kingdom.

5 With respect to metallurgical matters, the County has been using and continues to use the services of Professor Robert Anderson of San Jose State University; Professor Anderson's resume is attached in Annex C. Mr. Richard Hubbard of MHB Technical Associates and-Mr. Marc Goldsmith of Energy Research Group, Inc.

are also expert consultants of the County on EDG matters; their credentialskhave previously been furnished to this Board and the partiesintNisproceeding.

This level of resource commitment will contribute substan-tially to the development of a sound record in these proceedings.

The third criterion of Section 2.714(a)(1) therefore weighs heavily in favor of admission of the County's supplemental EDG contentions.

5. The extent to which the petitioner's participation will broaden the issues or delay the proceeding. The significance of the supplemental EDG contentions and their bearing upon the licensing proceeding have-been discussed above. The significance of these issues is so great that any delay required to litigate the supplemental contentions would clearly be justified. However, in the present circumstance there would be practically no delay occasioned by admission of the contentions. This is because neither LILCO nor the NRC Staff has completed its own investi-gation of the EDG problems, and will not do so for at least several months.

LILCO is conducting a so-called " revalidation program" of the EDGs which it does not expect to complete until mid-March. More importantly, the Staff is involved in an investigation of quality

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s assurance at TDI'through the Office of Investigation and of the EDGs under the NRR Plan. The latter investigation will involve publishing a supplementary SER on the EDGs, and is not expected to be completed before May 1984. These matters emphasize the signi-ficance which the Staff attributes to the EDG problems, and would have to be resolved before a low-power license could be granted

-for Shoreham in any case. See Suffolk County's Answer and Opposition to LILCO's Motion to set Schedule, December 23, 1983, at 4-6, 11-13, 16-17. Accordingly, the delay, if any, which might occur by admitting the County's supplemental EDG contentions would be minimal and far out-weighed by the significance of the issues presented.

It is therefore clear that all five criteria of Section 2.712(a)(1) for admitting late-filed contentions weigh in the County's favor. In addition, although technically not applicable, the criteria for reopening the record have been met; the foregoing discussion establishes that the County's motion is timely, that new evidence of significant safety questions exists, and that such evidence might materially affect the outcome of these proceedings.

See 17 NRC at 1141, 1143-44.

I l IV. LITIGATION SCHEDULING 4

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This Board's January 4 Order instructed the Caunty to address the issue of whether particular contentions are ripe for litigation in advance of completion of the several evaluations and investi^-

gations by the NRC Staff and by the NRC Office of Investigations.

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b For the reasons discussed below, the County believes that none of

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the supplemental E6'G contentions are ready for litigation, but that substantial discovery will be required and should commence.

In general, the County urges that the litigation of the

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supplementary EDG contentions not be fragmented. While the County has made an effort to divide the contentions into major cate-gories, material relevant to one contention necessarily will be related to that in other contentions. For example, product manufacturing defects (Contention III) may relate to design deficiencies (Contention II), where the design inadequacy is reflected by the difficulty in satisfactorily manufacturing a particular component to unrealistic design parameters. Both

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manufacturing and design inadequacies (Contentions III and II) are evidence of an ineffective TDI Appendix B quality assurance pro-gram (Contention IV), and may also be explained or understood by knowledge of what was or was not done under the QA program. The contention that the EDGs are undersized and over-rated (Contention I) may be related to'the inadequate design of other components (Contention II), or their unsatisfactory manufacture (Contention III), .and to general practices of TDI disclosed in the litigation of Contentions II, III and IV.

l l Similarly, the components of each particular contention are closely inter-related and inter-dependent. As explained in

. Professor Christensen's affidavit (Attachment 1 to Annex A), the elements of Contention I bear upon each other in a manner which defies separating them for litigation or other purposes. The design defects in the replacement crankshafts may be exacerbated l

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, by the problems with pistons and cylinder heads. Defects in the cylinder heads influence behavior of the pistons. In Contentions II, III and IV'the constituent elements of each directly support and relate to the others. The fragmenting of any contention would provide a most unrealistic approach to assessing the adequacy and reliability of the EDGs. The crux of each cuatention is not that any particular component or part of an EDG is or is not adequate, but rather that the entire diesel engine -- its parts and the manner.in which they affect each other and EDG operation -- is unreliable and inadequate.

In addition-to the foregoing substantive-reasons for not having a fragmented and piecemeal litigation of the supplemental EDG contentions, there is a very practical problem. It would place an extreme and unfair burden.on the County to require its team of lawyers and technical experts simultaneously to conduct f litigation of one contention and conduct discovery and prepare testimony on other contentions.

The NRR Plan indicates that the Staff is beginning a compre-hensive investigation of the reliability of TDI diesels. We believe that the Staff is in the process of retaining additional

( outside consultants for this purpose. Information resulting from t

this Staff investigation is likely to be highly relevant to the County's EDG contentions and should be reviewed by all parties

before litigation commences. Moreover, the Staff's investigation 1

could lead the Staff to conclude that the EDGs at Shoreham must be replaced before a low power license can be granted. Such a final G .

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6 determination by the Staff might eliminate the need for lengthy 0

and costly litigation.

The results of the investigation by the Office of Investi-gations ("O.I.") of quality assurance at TDI could have a direct and material bearing upon Contention IV. O.I. has refused to ,

disclose any information regarding QA at TDI in order not to compromise its investigation. This precludes the County from obtaining from O.I. material likely to be important and relevant to Contention IV. Therefore, forcing the County to litigate Contention IV prior to release of 0.I.'s conclusions would prejudice the County.

Aside from the foregoing matters, there is the unusual fact that LILCO has not completed its own evaluation of the EDGs. The results of LILCO's " design review and quality revalidation pro-gram" are estimated to be completed in mid-March. The torsional stress tests on the replacement crankshaft on EDG 103 have not been completed and reported. FaAA has not issued its report on the cause(s) of the piston failures or on the adequacy of the model "AE" replacement pistons. No testimony should be required to be filed until these matters are completed and reviewed by all parties. They may disclose that the EDGs should be replaced, a

( result which obviously would affect whether litigation is necessary.

All of the facts discussed above -- the inter-relationship of the supplemental EDG contentions, the close dependency of consti-tuent elements of each contention, the substantive injustice to the contentions and the severe burden on the County which would

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% L result from fragmenting the EDG litigation, the lack of relevant information due to the non-completion of Staff EDG evaluations and the O.I. investigation of TDI, and the non-completion of LILCO's

, own EDG evaluations -- demonstrate that litigation of the EDG contentions should be deferred. There is no legitimate reason which outweighs these factors. Forcing the parties to commence fragmented and premature litigation would prejudice,Suffolk County and not serve the public interest.

Suffolk County estimates that substantial document discovery remains to be initiated and completed regarding the issues ad-dressed by the supplemental EDG contentions.5! Thereafter, the County anticipates that a large number of depositions will need to be taken, altho' ugh the exact number will depend in part upon additional document discovery. Assuming the supplemental EDG contentions are admitted, the County intends to proceed with additional document discovery requests expeditiously.

Respectfully submitted, Martin Bradley Ashare, Esq.

Suffolk County Department of Law i

Veterans Memorial Highway Hauppauge, New York 11788 1

=e-Herbert H. Br % jf Lawrence Coe/Lanpher Alan Roy Dynner KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 January 27, 1984 Attorneys for Suffolk County 5/ We note for the record that documents concerning TDI cylinder heads ordered to be produced by this Board's Order of August 25, 1983 and requested by the County on August 23, 1983, have still not been produced by LILCO or TDI.

ANNEX A SUFFOLK COUNTY SUPPLEMENTAL EDG CONTENTIONS Preamble The General Design Criteria ("GDC") for Nuclear Power Plants, 10 C.F.R. Part 50, Appendix A, establish certain mini-mum requirements for the principal design criteria for the Shoreham Nuclear Power Station. In particular, GDC 17 requires LILCO to provide an onsite electric power system that permits

" functioning of structures, systems and components important to safety" and that is of " sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as.a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital ~ functions are maintained in the event of postulated accidents."

LILCO's licensing ccmmitments set forth in the Shoreham FSAR, Section 8.3.1, require, inter alia, that each of three diesel generators constituting the Shoreham onsite standby electric power system be rated as follows:

Continuous (8,760 hr) 3,500 kW 2 hr per 24 hr period 3,900 kW The 2 hr rating in any 24 hr period is the rating without reducing the maintenance interval established for the continuous rating. ,

(FSAR Section 8.3.1.1.5).

To assure adequate emergency response for the loss-of-coolant accident with the simultaneous loss of off-site power, two out of three diesels must operate on the signal. This requires a greater level of reliability than most plants which require one out of two emergency diesel generators to operate.

The supplemental EDG contentions deal with the entire die-sel engine and the dynamic inter-relationship of its parts and components. An effort has been made to characterize specific facts under each contention as particularly related to the subject matter of the contention, e.g., as a design deficiency or a manufacturing defect. However, it is in many cases difficult, if not impossible, to determine if a particular fact or event evidences only a design deficiency (Contention II),

only a manufacturing defect ( Contention III), only a quality assurance problem (Contention IV), or a combination thereof.

Moreover, a number of design or manufacturing defects relate to the fact that the diesel engines at Shoreham are undersized and over-rated to adequately perform their intended function (Con-tention I). The four contentions are thus integrated, repre-senting the general proposition that the emergency diesel engines at Shoreham are not reliable or capable of operating as .

required.

CONTENTION I - THE EMERGENCY DIESEL GENERATORS ARE OVER-RATED AND UNDERSIZED I. Contrary to the requirements of GDC 17 and FSAR Section 8.3.1, the emergency diesel generators at Shoreham

("EDGs") manufactured by Transamerica Delaval, Inc. ("TDI")

cannot adequately perform their required functions because they are over-rated and undersized. There can be no reasonable as-surance that the EDGs will perform satisfactorily in service at 3,500 kW or higher power and that such operation will not result in failures of additional parts and components of the E DGs . The EDGs must therefore be replaced with engines of greater size and capacity. -

I. A. Contention I is demonstrated by the following factors (see Attachments 1 and 2, the Affidavits o'f Professor Stanley G. Christensen and of George Dennis Eley, for the bases for these factors):

1. The original crankshafts in the EDGs were unable to operate under the stresses to which they were subjected; one crankshaft broke in half and the other two were cracked (Board Notification 83-160, 10/21/83). The replacement crankshafts currently installed in the EDGs are incapable of operating for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period at overload (3,900 kW) as required by FSAR Section 8.3.1.1.5, without the development of a nuclea-tion site, and the design of those crankshafts is marginal for operation at 3,500 kW.

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, 2. The replacement crankshafts currently installed in the EDGs, because of their greater weight and the effect of

" crankshaft whirl," will cause excessive wear on the main bearing between the number 4 and number 5 cylinders, loosening of the main bearing, and crankshaft misalignment.

3. At Shoreham 23 of 24 pistons (model "AF") in the .

three EDGs were found to be cracked. (LILCO Diesel Generator Status Report ( "DGS R" ) 11/17/83; 10 C.F.R. Part 21 Report, TDI, 11/16/83). This 96% failure rate evidences a serious design deficiency in the pistons, which could not withstand the firing i

pressures to which they were subjected at the rated operating power of the EDGs. The replacement pistons (model "AE")

installed in the EDGs are also of inadequate design to with-stand operating conditions. Further, the model AE piston is unproven.

4. Cylinder heads installed in the EDGs cracked during

, , operation and were replaced with cylinder heads of the same design but allegedly better quality. The replacement cylinder heads are of inadequate design and manufacture to withstand j sat.isfactorily thermal and mechanical loads during EDG l

j operation.

i

5. The inter-relationship of the crankshaft, pistons, l

and cylinder heads and other components during operation may exacerbate the weaknesses of major components.

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~I.B. Contention I is further supported by the following observations at Shoreham and experience with other TDI diesels (see Attachments 1 and 2):

1. Exhaust temperatures for the EDGs are very high (ap-proximately'1100*F.) and indicative of over-rating., t

2. The operating experience of TDI diesel engines (similar to the EDGs) on the ship M.V. Columbia discloses many -

of the same problems as occurred in the Shoreham EDGs. The TDI diesel engines on the Columbia were de-rated to increase reliability in response to those problems. (Evaluation of the Operational and Maintenance History of, and Recent Modifica-tions to, the Main Engines in the M.V. Columbia, Seaworthy l Engine Systems, Inc.,-April 1983 (" Seaworthy Report") ) .

j

3. The EDGs have experienced excessive vibration and variations in the vibration levels among the three EDGs. (NRC

I&E Report 83-07). Such vibration may indicate that the EDGs are over-rated and undersized.

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', CONTENTION II - IMPROPER DESIGN II. Contrary to GDC 17, various components of the EDGs l

l are not properly designed to operate reliably and to adequately r'

perform- their required functions. Accordingly, there can be no reasonable assurance that the EDGs will perform satisfactorily in service and that there are not additional design deficiencies which will result in failures of other parts or components of the EDGs. The EDGs must therefore be replaced with engines not designed by TDI.

II.A. Contention II is demonstrated by the following

design deficiencies in the EDGs (in addition to those specified in Contention I.A. relating to the crankshafts, pistons and cylinder heads):

1. Connecting Rod Bearings. Four upper connecting rod bearings were cracked, in part due to improper design (Emergen-

cy Diesel Generator Connecting Rod Bearing Failure Investiga-tion, Failure Analysis Associates ("FaAA"), 10/31/83). This deficiency has only been partially remedied and will not ensure correct lubrication and freedom from problems.

I I 2. Jacket Water Pumps. Scoring indications were found in the jacket water pump for EDG 102, caused by slippage of the impeller on the shaft. (10 C.F.R. Part 21 Report, TDI, j 7/20/83; Inspection of Jacket Water Pumps from TDI Engines, I

I l

L . , . _ _ ,-_ _ _ _ _ _

. FaAA, 12/15/83). The jacket water pump is improperly designed because its location exacerbates the deleterious effect of vi-brations. .

3. Rocker Arm Assembly Holddown Capscrews. A rocker arm assembly capscrew failed due to inadequate design. The capscrew was redesigned and modifications were made to the rocker arm holddown assembly. (10 C . F. R. 50.55(e) report, LILC O, SNRC-883, 5/4/83). These design changes transfer the shear loading from the rocker shaft bolts to, and may overstress, the cylinder head sub-assembly.

4. High Pressure Fuel Lines. The improper design of the high pressure fuel lines permitted the possibility of a fire during failure, because the fuel lines were not shrouded.

(10 C.F.R. 50.50(e) report, LILCO, 5/20/83; 10 C.F.R. Part 21 Report, TDI, 7/20/83).

5. Starting Air Valve Assembly. The capscrew which holds the starting air valve assembly in the cylinder head was too long. This design defect could cause the assembly to fail and the engine to fail to start or the joint between the valve and the cylinder head to leak gasses if the capscrew bottomed the tapped hole in the cylinder head before the assembly is seated. (10 C.F.R. Part 21 Report, TDI, 5/13/83).

, 6. Electrical Cables. The engine-mounted electrical cables may exceed the manufacturer's temperature rating during operation at Shoreham and other plants. (10 C.F.R. Part 21 Report, TDI, 9/27/83).

7. Camshaft Lobes. Exfoliation of the hardened surface material on camshaft lobes on EDG 101 is evidence of improper design. (LILCO DGSR, 10/20/83).

8. Turbocharger Thrust Bearings. The design of the lubricating oil system at Shoreham and other plants was defec-tive because the system was by-passed when the engine was not running, potentially damaging the turbocharger thrust bearings.

(10 C.F.R. 50.55(e) report, Cleveland Electric Illuminating Company, 1/27/81; 10 C.F.R. 50.55(e) report, LILCO, SNRC-549, 3/27/81). The design has been modi.fied, but coul'd lead to

-blockage of oil.

9. Air Supply Tubing. Excessive vibration in air supply tubing and turbochargers resulted in failures in these and re-lated components. Excessive vibration is indicative of pocr

. design and manufacturing. (Lett,er from R.A. Pratt (TDI) to J.C. Kammeyer (SWEC) (S/N 74010/12), 4/21/83).

10. Base Plates. Cracks were found in different loca-tions in the base plates of EDGs 102 and 103. (LILCO DGSR, 9/21/83; NRC Region I Morning Report, 9/7/83; Memorandum to

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J

• M.H. Milligan/W.M. Judge (LILCO) from C.H. Wells (FaAA),

12/7/83).

11. Turbocharger Bolts. Turbocharger hold down bolts .

failed due to improper clamping force or seizure of the bolts (Letter to N. Rudikoff (LILCO) from W.L. McHugh (TDI), 9/19/83

( "McHugh Letter") ) , thus indicating a design deficiency in the bolt.

12. Cylinder Liners. Pitting occurred in some cylinder liners in all three EDGs. (McHugh Letter; LILCO DGSR, 10/20/83).

13. Design Modifications. The following additional design modifications were recommended by TDI after the EDGs had beep installed at Shoreham. The need for these design modifi-cations further reflects the deficiencies in the design of the TDI EDGs :

(a) Governor Linkage: incorporated collapsible link style assembly; (b) Cylinder Block and Liners: installed special nuts for lifting fixture, and viton "O" rings; i (c) Fuel Oil Header; installed ejector system;

, (d) Turbocharger Bracket: installed improved and l

strengthened bracket; E

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. (e) Cylinder Head Shud: recommended improved stud design with improved fatigue characteristics; (f) Lube Oil Pressure Regulating Valve: recommended improved design clearance-modified to prevent

~l sticking; 1

(g) Control. Systems: recommended incorporating vibration and temperature main bearing shutdown instrumen-tation;

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(h) Governor Drive Coupling: recommended softer drive coupling; (k) Air Butterfly Control Bearing: recommended modifica-tien t of butterfly values that have experienced fail-N ures; and

. (j) Idler Gear: recommended modification in the design of the idler gear which had resulted in an increase of gear / thrust wear in non-nuclear service.

( Memorandum to E. J. Youngling from R.J. Jaquinto, 9/23/83; Letter to J.C. Kammeyer (SWEC) from R. A. Pratt (TDI), 6/7/83);

letter from W.L. McHugh (TDI) to E. J. Youngling (LILCO),

9/21/83).

II.B. Contention II is further demonstrated by design deficiencies in'TDI diesel generators (essentially-identical or l

similar to the EDGs) at other nuclear plants, as follows:

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1. Spherical Washer Subassembly. Three of four spheri-cal washers attached to a piston at Grand Gulf failed in part due to inadequate design. (10 C.F.R. Part 21, TDI, 11/5/81; 10

. C . F . R. 50.55(e) report, Mississippi Power & Light Co.,

4/15/82).

2. Governor Lube Oil Cooler Assembly. The governor lube oil cooler assembly was defectively designed to be located in a position such that air potentially could be trapped in the system. ( 10 C . F. R. Part 21, TDI, 12/9/81).

3. Connecting Push Rod Weld. A connecting push rod weld on one of the cylinders at Grand Gulf separated into two pieces due to incorrect material specification. (Responses to Power Systems Branch Requests for Additional Information, Delaval Diesel Generator Evaluation, Grand Gulf Units 1 & 2, Mississippi Power & Light Co., 11/4/83 (" Grand Gulf Re-sponses")).

4. Jacket Water Pipe Welds and Turbocharger Mounting Bolts. Failures of these components occurred at Grand Gulf as a result of high turbocharger vibration levels, which are in-dicative of defective design. (Grand Gulf Responses) .

5. Air Start Valves. Air start valves failed at Grand i

Gulf on two occasions due to a design defect. (Grand Gulf Re-sponses).

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6. Non-Class IE_ Control Power and, Components. Non-class

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power war.

used to operate contirol devi,ces and non-class IE control'cyomponents'were used in circui,ts at Perry, a design de- "

,'fidiency. ( Applicants' . Answer. to Chio Citizen for . Responsible

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Energy Motion to Resubmit its contention No. 2, Cleveland

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E,lectric Illuminatine; Co'. , ,10/3 /83 ) .

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7. / Crankcase Capscrews .1 , At Grand Gulf, a sheared bolt r f i*

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on the re.ar crankcase cover failed due to a combination of met-e allurgical and vib' rational factots, causing a generator short j'l e circuit. (Gr;tnd Gulf Responses) . This deficiency was caused in

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'partj'by a design defect. ,'

. ' Fuel Oik/ Line. A -Gra d Gulf, the main fuel supply tubing failNd!. ; Crack. initiation,, propagation and ultimato

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, failure were determined to be due to high cycle fatigue, hequiring redesign. , (G: and Gulf Responses) .

1 9. Sensi'ai;r Line. Tito \r pressure sensing l.ine yetween the 1

<: . s

, starting air storage tan,h, and the starting ad.r c),apressor was not seismically suppor,ted,at t Grand Gulf, requiring. <,

redesign.

(10 C.F.R. Part 21 Report, bDI, 3/19/82; 10 C.F.R. 50.55(e)

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.reporth Missi,ssippi Power N LightseC5.; 3/8/82). .

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/ 10. Class IE Cable. Commercial grade wire had be'en used irt pitce of as Class;IE cable in certain engine and panel'

~ c'ircuits at Perry,e' a design deficiency.

This cable failed the T

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e IEEE 383 Insulation Flame Test. (10 C.F.R. 50.55(e) reports, Cleveland Electric Illuminating Company, 12/22/82, 3/30/83, 9/15/83, 9/27/83).

11. Link Rod Assembly. The dowel countorbore in the link rod assembly was incorrectly designed to be too shallow. (10

. C . F. R. Part 21 Report, TDI, 9/19/80).

12. Governor Flexible Drive Coupling. The design of the flexible drive element which couples the engine and the gover-nor at Catawba was defective. The element material deterio-rates rapidly and fails under normal operating conditions. (10 C . F . R. Part 21, TDI, 6/23/82 10 C.F.R. 50.55(e), Duke Power Co., 10/8/82).

13. Rotor and Stator. The rotor, stator and AC box at the Shearon ' Harris plant had dimensional, electrical and speci-fication deficiencies. (10 C.F.R. 50.55(e), Carolina Power & ,

Light Co., 8/18/83).

14. Air Check Valves. Air check valves furnished by TDI leaked due in part to a design defect. (10 C.F.R. Part 21 Report, TDI, 11/5/81).

15. Pneumatic Logic. At Grand Gulf, the pneumatic logic was improperly designed so that the engines may inadvertently shut down under certain conditions. (10 C . F. R. 50.55(e) report, Mississippi Power & Light Co., 2/1/82).

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16. Relay Tachometer. An improper design of the voltage  ;

regulation circuit of the relay tachometer due to a mantifacturing specification change caused the relay tachometer to fail at Grand Gulf. (10 C . F. R. 50.55(e) report, Mississippi Power & Light Co. , 8/9/82).

II.C. Contention II is further demonstrated by design deficiencies in TDI diesels (essentially identical or similar to the EDGs) in non-nuclear (marine)' applications, as reported by the State of Alaska (M.V. Columbia), Titan Navigation (M.V.

Pride of Texas, M.V. Star of Texas) and U.S. Steel (M.V. Edwin H. Gott) ships, as follows:

1. M.V. Columbia.

1. Pistons. Failures of bolting mechanisms and crown-to-skirt oil seals in the pistons are attributed to TDI design deficiencies. (Seaworthy Report) .

2. Piston Rings. Piston rings required frequent change out and scrapping due to accelerated wear and chrome flaking .

embedded in the piston crown, caused in part by inadequate design. (Seaworthy Report) .

3. Cylinder Heads. Cylinder heads had a very high fail-ure and removal rate due to inadequate design. Design failures include head cracking and fire deck warping (Seaworthy Report) .

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l e 4. Cylinder Liners. Cylinder liners had a very high re-moval and failure rate due in part to inadequate design.

Problems have included: gallfng and scoring, premature wear, and liner deformation due to cylinder block deformation.

Chrome flaking, incomplete combustion and operational problems ,

appear to have caused these deficiencies. (Seaworthy Report) .

5. Master Link and Connecting Rods. Connecting rods and related components cracked and failed due to high stress load-ings, evidence of inadequate design. (Seaworthy Report) .

6. Cylinder Blocks. Cylinder blocks cracked due to the .

high stresses from the cylinder head hold down forces, evidence of inadequate design. (Seaworthy Report) .

7. Turbochargers. Turbocharger failures include leaking oil / air seals, bearings, nozzles, rotors / cracked casings and

- fasteners. Turbochargers could not deliver a high enough quan-tity of air at an acceptable manifold pressure. These i

deficiencies indicate inadequate design. (Seaworthy Report) .

8. Camshafts. Cam lobes were worn beyond acceptable limits and had to be removed, evidencing inadequate design.

(Seaworthy Report) .

i

( 9. Main Bearings. Main bearings were prematurely worn due to high carbon loading imposed on the lube oil. The lube L

oil system was unable to continuously purify the lube oil and l

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8 remove carbon particles.

These deficiencies indicate that the main bearings were inadequately designed. (Seaworthy Report).

10. Exhaust Valve Guides. Carbon build-up on the valve stems caused stuck valves and guide damage. Pieces of guide valves broke off. The root causes of these deficiencies have not been determined (Seaworthy Report), but a design deficiency is clearly a potential cause.

11. Connecting Rod Bearings. Connecting rod bearings had excessive wear and cracked, indicative of poor design. (Letter from M. Zbinden to W. Hudson, 2/2/79; letter to J. Eide from A.

MacDonald, 12/26/79).

12. Major overhauls. The M.V. Columbia engines have been

overhauled at a rate four times greater than expected by TDI or any other diesel manufacturer, indicating that the engines are improperly designed. (Seaworthy Report) .

ii. M.V. Pride of Texas

1. Cylinder Head Exhaust Valves. Stellite valve seats l in the cylinder heads cracked from exhaust valve failures due i

to improper cylinder head design for heavy fuel use. (Attach-ment A to letter from C.C. Wei, Falcon Carriers, Inc. to C.

Matthews (TDI), 7/22/82 (" Falcon Report") ) .

2. Fuel Cam. The fuel cam roller " rides" either at or over the edge of the cam, greatly stressing both the lobe and l

4 O

the roller, an indication of inadequate design. (Falcon Report).

3. Camshaft Roller. The tappet assembly rollers were severely galled, in part due to defective design in the cam-shaft and lobe placement. (Falcon Report) .

4. Piston Pins. The chrome plating flaked off the pis-i ton pins. Chrome plating was oelieved to have added stress into the surface of the pin. These deficiencies are evidence of inadequate design. ( Falcon Report) .

5. Intercoolers. All four intercoolers failed due to erosion of the tubes caused by fluid velocity and debris in the fresh water system, a design deficiency. ( Falcon Report) .

6. Air Start Valves. Several valves failed for unknown reasons, which could be design-related. ( Falcon Report) .

7. Couplings and Clutch Assembly. Excessive engine vi-bration resulted in failures of these components, indication of inadequate design. ( Falcon Report) .

8. Crankshaft Plugs. Crankshaft plugs cracked from im-proper use of gauge material, which could be a design deficien-cy. (Falcon Report) .

9. Fuel Oil Return Lines. Failures occurreJ due to the inadequately designed wall tubing. ( Falcon Report) .

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s 10. Control System. Signals were not identified by the control system circuitry, evidence of inadequate design. (Fal-con Report) .

11. Cylinder Block. The cylinder block failed and cracks were observed at various locations, indicative of possibly in-adequate design. ( Re port No . EAI-81-2539, M.V. " Pride of Texas," American Bureau of Enipping, 12/16/81).

12. Pistons. Piston skirts cracked due to inadequate design. (Falcon Report) .

13. Cylinder Liners. A cylinder liner cracked, possibly due to inadequate design. ( Falcon Report) .

1 111. M.V. Star of Texas

1. Cylinder Heads. Cylinder heads cracked due possibly to inadequate design. (Letter to J. L. McGlashan from R.

Jaegersen, 4/1/83).

2.

Pistons. Piston skirts cracked at the termination of the fillet radius due to a design deficiency. (American Bureau l of Shipping Report No. HAI-82-2600, 8/19/82).

3. Clutch. The clutch failed due to excessive vibration i

l caused by an undetermined deficiency in design, manufacturing i

l and/or installation. (Letter to J. Barrios (Livingston Shipbuilding Co. ) from H. Glennon (Titan Navigation), 6/17/81).

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4. Turbochargers. Turbochargers experienced difficulty supplying sufficient air, possibly attributable to a design de-ficiency. (Letter to J. L. McGlashan from R. Jaegersen, 4/1/S3).

iv. M.V. Edwin H. Gott Cylinder heads cracked (Minutes of meeting between U.S. Steel and TDI, 11/20/80), which is in-4 dicative of poor design.

CONTENTION III - UNSATISFACTORY MANUFACTURING III,. Contrary to GDC 17, the EDGs are not satisfactorily manufactured to operate reliably and to adequately perform their required functions. Accordingly, there can be no reason-able assurance that the EDGs will perform satisfactorily in service and that there are not additional manufacturing defects

(

N in the EDGs which will result in failures of other parts or components of the EDGs. The EDGs must therefore be replaced with engines not manufactured by TDI.

III.A. Contention III is demonstrated by the following manufacturing defects in the EDGs (in addition to those relating to cylinder heads specified in Contention I.A.4 and affidavits in support thereof):

1. Cylinder Heads. Cylinder heads cracked, due in part to poor casting techniques. (10 C.F.R. 50.55(e), LILCO, 4/15/83).

2. Connecting Rod Bearings. Failure of the connecting I

rod bearings was caused in part by voids due to improper manufacturing techniques. (Emergency Diesel Generator Connecting Rod Bearing Failure Investigation, FaAA, 10/31/83; Analysis of the Replacement Connecting Rod Bearings for Emer-gency Diesetl Cenerators, Fatigue Life Prediction, FaAA, 12/15/83).

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. 3. Pistons. Cracking in 24 of 26 pistons was caused in part by poor manufacturing techniques. (10 C.F.R. Part 21, TDI, 11/16/83; Preliminary Metallurgical Analysis of Cracked i

\

Piston Skirts from Emergency Diesel Generators, Shoreham Nucle-ar Power Station, FaAA, 12/8/83).

4. Fuel Line. The high pressure fuel line failed due to a crack that propagated from a tool mark. A similar failure ,

occurred at Grand Gulf, causing a fire. (10 C . F. R. 59.55(e),

LILC O, SNRC-892, 5/20/83; 10 C . F. R. Part 21 Report, TDI, 9/21/83).

5. Generator Rotor. Mechanical damage to the insulation on the rotor pole caused low megger readings, caused in part by a sharp corner located close to the window and by the marginal quality of workmanship in fabrication of the pole piece.

(LILCO DGSR, 10/20/83; FaAA Report EF-3060, 10/22/83).

6. Cylinder Liners. A grcove was found on a cylinder liner, which was attributed to improper machine shop processes.

(LDR 1642; McHugh Letter).

7. Cylinder Head Subcover Assembly. Cracks occurred in the web of the bridge between the two sides of the subcover l

assembly at the fuel injector indentation. (LDR 1541; letter l

from W.M. McHugh (TDI) to N.M. Rudikoff (LILCO) 8/3/83) .

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• 8. Cylinder Head Nuts. The failure of two cylinder head nuts was attributed to a manufacturing defect. (Memorandum from L.A. Swanger ( Fa AA) to M.H. Milligan (LILCO), 11/25/83).

9. Engine Lube Oil Line. A mandatory hole was not drilled through the pipe due to a shop fabrication error.

(Letter to J.C. Kammeyer (SWEC) (S/N 74010/12) from R.A. Pratt (T DI ) , 4/21/83).

10. Camshaft Lobes. Exfoliation of the hardened surface material on campshaft lobes on EDG 101 may have resulted in part from ineffective heat treatment, a manufacturing deficien-cy. (LILCO DGSR 10/20/83).

11. Fuel Injectors. Several injector tips were improp-erly manufactured. (Emergency Diesel Generator Connecting Rod Failure Investigation, FaAA, 10/31/83; Analysis of the Re-placemnt Connecting Rod Bearings for Emergency Diesel Genera-tors, Fatigue Life Prediction, FaAA 12/15/83).

12. Other De fects. Manufacturing defects in the EDGs are also evidenced by the specific matters described in paragraphs 9, 10 and 12 of Contention II.A.

III.B. Contention III is further demonstrated by manufacturing defects in TDI diesel generators (essentially identical or similar to the EDGs) at other nuclear plants, as follows:

. - _ _ _ _ _ - _ _ _ _ - - . . - . _ - - ~ - . - . . - - i

I

, 1. Piston Skirts. Residual stress caused by the improp-er method of heat treating of piston skirts could result in cracking. (10 C.F.R. Part 21 Report, TDI, 10/28/82).

2. Spherical Washer Subassembly. At Grand Gulf a pis-ton crown partially separated from the piston skirt due to the failure of one of the four attachment stud bolts, caused in part by an improperly manufactured spherical washer subassembly. (10 C.F.R. 50.55(e) report, Mississippi Power &

Light Co., 4/15/82).

3. Valve Springs. Valve springs installed on the engine cylinder head assembly were improperly manufactured. (10 C . F. R. , Part 21 Report, TDI, 7/30/81).

4. Other Defects. Manufacturing defects in TDI diesels at other nuclear plants are also evidenced by the specific mat-ters described in paragraphs 1, 4, 7, 8 and 14 of Contention II.B.

III.C. The unsatisfactory manufacture of the EDGs is further demonstrated by manufacturing defects in TDI diesels (essentially identical or similar to the EDGs) in non-nuclear applications, as follows:

l

i. M.V. Columbia.

1. Cylinder Heads. Cylinder head cracking, fire deck warping, contaminant inclusion, and coreshifting were caused in part by poor casting techniques at TDI. (Seaworthy Report) .

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2. Other Defects. Manufacturing defects are also evi-

+

danced by the specific matters described in paragraphs 2, 3, 4, i 5, 6, 7, 8, 9 and 10 of Contention II.C.i.

ii. M.V. Pride of Texas.

1. Camshaft Rollers. The tappet assembly rollers were severely galled due in part to inadequate heat treatment. j 1

(Falcon Report) .

2. Fuel Cam Lobes. Two fuel cam failures occurred due i

to improper heat treatment of the lobes by TDI. (Falcon Report).

3. Pistons. Stress risers were observed in pistons; one piston disintegrated due to a riser. (Falcon Report) .

4. Cylinder Liners. One cylinder liner was scuffed, possibly due to poor manufacturing. (Falcon Report).

5. Other De fects. Manufacturing defects are also evi-denced by the specific matters described in paragraphs 4, 6, 7, 8, 11, 12 and 13 of Contention II.C.ii.

iii. M.V. Star of Texas. Manufacturing defecta are also I

evidenced by the specific matters described in paragraphs 1, 2 .

and 3 of Contention II.C.iii.

iv .' M.V. Edwin H. Gott (U.S. Steel) Cylinder heads cracked, which was attributed to casting stresses and aeration problems. (Minutes of meeting between TDI and U.S. Steel, I 11/20/80).

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' CONTENTION IV - QUALITY ASSURANCE

+

IV. Contrary to the Quality Assurance Criteria for Nucle-ar Power Plants, 10 C.F.R. Part 50, Appendix B (" Appendix B"),

LILCO, directly or through its contractors, agents or consul-tants, failed to assure that TDI designed and manufactured the EDGs (including their components and replacement components) ,

under an effective appendix B quality assurance ("QA") program, and TDI in fact failed to design and manufacture the EDGs (including their components and replacement components) under an effective Appendix B QA program. Accordingly, contrary to

'the requirements of GDC 17 and Appendix B,.there can be no adequate confidence that the EDGs will operate reliably and with sufficient capacity and capability to adequately perform their required functions and that additional parts and compo-nents of the EDGs will not fail. The EDGs therefore must be replaced with engines not manufactured by TDI.

IV.A. TDI's failure to desigr. and manufacture the Shoreham EDGs under an effective Appendix B QA program is dem-onstrated by the deficiencies and defects listed in Contentions j

I, II and III above, each of which would have been prevented or detected by such an effective program.

IV.B. TDI's f ailure to design and manufacture the EDGs l

under an effective Appendix B QA program is further

i

. .'emonstrated 2 by the following QA deficiencies in TDI diesels essentially identical or similar to the EDGs (in addition to those listed in Contentions I, II and III) each of which would have been prevented or detected by such an effective program:

1. Improper ASME Code Piping Welds in Jacket Water Pipes ati Perry. At Perry, jacket water and lube oil pipes had welds that violated ASME Section III requirements. (10 C.F.R. 55(e) reports, Cleveland Electric Illuminating Co., 4/28/82, 9/24/82, 4/1/83, 7/1/83).

2. Cam Gear Case. Installation of the fitted cam gear bolts was not verified due to an error in shop QA procedures.

(Letter to J. C. Kammeyer (SWEC) from R. A. Pratt (TDI) (S/N 740ld/12), 4/21/83),

3. Engine Governor. Proper alignment of the engine gov-ernor drive was not verified due to an error in shop OA proce-dures, placing excessive stress on the governor drive coupling, breaking the drive grid and causing the drive shaft key /keyslot to wear. (Letter to J. C. Kammeyer (SWEC) from R. A. Pratt (TDI) (S/N.74010/12), 4/21/83).

4. Engine Crankshaft Thrust Clearance. Excessive crank-shaft thrust was caused by excessive shear loads on the main bearing cap dowels during railroad shipment of the engine to site. (Letter to J. C. Kammeyer (SWEC) from R. A. Praft (TDI)

(S/N 74010/12), 4/21/83).  ;

9 -

, - , , ---..w, ,.7 . , . - , , . . - , , , , , , , , ,-.wn ,n,--,.mm,-,._a ,e , -. - , - y

', 5. Battery Racks. Battery racks supplied by TDI at Ca-tawba were not seismically qualified and the welding was deemed questionable. (10 C.F.R. 50.55(e) report, Duke Power Co.,

8/29/80).

6. Pump Motors. TDI' furnished unqualified motors at Grand Gulf which failed to comply with Bechtel's purchase order. 10 C. F. R. 50. 55 ( e) report, Mississippi Power & Lighting Co., 4/29/81).

7. Air Check Valves. Air check valves manufactured by Wm. Powell Company and furniched by TDI leaked. (10 C.F.R. Part 21 Report, TDI, 11/5/81).

8. Heat Exchanger Baffling. Internal baffling of the diesel generator heat exchangers had the wrong dimensions on the engineering drawings. The baffling was supplied but not manufactured by TDI. (10 C.F.R. 50.55(e) report, Duke Power Co., 3/7/80).

9. Thrust Bearings. A shim required to maintain clear-ance at the thrust bearing on one diesel at WPPS was missing, causing failure of diesal generator lA.because of excessive end clearance. Diesel Generator 1B failed because it had been im-properly assembled following a line bearing failure. (10 C . F. R. 50.55(e) report, Washington Public Power Supply System, 11/4/83).

_ _ c m

( 10. Primary Knife-Type Disconnect. TDI supplied a defec-tive knife-type disconnect in certain engines at River Bend.

The disconnect was not manufactured by TDI. (10 C.F.R. 50.55(e) repo rt, Gulf States Utilities Co., 5/27/83).

11. Pipe Supports. Piping supports supplied by TDI at Comanche Peak did not meet ASME code requirements. (10 C.F.R. 50.55(e) report, Texas Utilities Generating Co., 10/21/80).

12. Governors. One governor was rebuilt incorrectly after it was returned to the subvendor for inspection; another governor was furnished in the wrong assembly condition. (10 C . F. R. Part 21, TDI, 8/10/83).

13. Valve Springs. At River Bend, valve springs that were installed on the engine cylinder head assembly by TDI and manufactured by a subvendor had been manufactured improperly.

(10 C.F.R. 50.55(e), Gulf States Utilities Co., 10/5/81).

14. Anchor Bolts and Nuts. The EDG engine anchor bolts and nuts supplied by TDI at Shearon Harris were not identifiable by type and grade because the markings stamped on the bolts and nuts were not consistent with industry standards.

(10 C.F.R. 50.55(e) report, Carolina Power & Light Co.,

2/17/83).

15. Rocker Arm Hold Down Bolts. Rocker arm hold down bolts on one cylinder he'ad subcover failed during testing of n, .

n- - - -e -~

e

. EDG 101, causing damage to the cylinder subcover assembly. The test engineer had written a test exception which allowed the by-passing of the assembly procedure Which required torquing of the_ bolts. (PNO-1-84-01, 1/3/84, 1/4/84).

IV.C. TDI's failure to design and manufacture the EDGs under an effective Appendix B OA program is further demon-strated by the deficiencies in the OA process indentified in the audit reports of Stone & Webster Engineering Corp. ("S&W")

on behalf of LILCO, and in reports by or for the NRC Staff, as follows:

1. NRC Vendor Inspection Reports. During seven vendor inspections at TDI, the NRC Staff documented numerous instances of regulatory violations and nonconformances (NRC Vendor In-spection Reports 79-01 (3/5-9/79); 80-01 (10/14-17/80); 81-01 (4 /6-8/dl) ; 81-02 (7/13-16/81); 82-01 (1/25-29/82); 82-03 (8/23-26/82); 83-01 (7/11-15/83). Following vendor inspection 83-01, the NRC staff identified " conditions Which imply that portions of the TDI OA program have not been carried out in ac-i l cordance with the provisions of 10 CFR 50, Appendix B." (Board Notification 83-160, 10/21/83). A summary of NRC vendor in-spection reports of TDI is attached as Attachment 3.

l 2. Board Notification 83-160 (10/21/83). In Board Noti-fication 83-160, the NRC Staff noted "the occurrence of many 1

y _ _ _ _

minor problems with TDI EDGs," the number of which " appears to be abnormally high." The Staff indicated that "the identifica-tion of QA problems at TDI, taken together with the number of operational problems and the Shoreham crankshaft failure, has reduced the staff's level of confidence in the reliability of all TDI diesel generators." Additional data may be developed by the ongoing investigation by the NRC Office of Investiga-tions into QA irregulatories at TDI.

3. NRC I&E Inspection Reports. In NRC I&E reports con-cerning Shoreham since November 30, 1982, the NRC staff has identified at least eight instances of OA violations and potential violations. (NRC I&E reports 82-35 (11/30-12/31/82);

83-02 (1/10-1/15/83); 83-10 (4/1-5/9/83 ); 83-21 ,

(6/22-7/27/83).)

4. The three Shoreham EDGs were fabricated, tested and shipped before TDI had implemented the QA measures required by the S&W audits. S&W conducted an audit of TDI from October 28 to 30, 1975. Reaudits of the corrective measures required of TDI were conducted on February 23 and June 18, ,1976. Th. audit and reaudit reports concluded that TDI had failed to fully com-ply with the requirements of its own OA Manual and Appendix B.

The three EDGs, however, were fabricated, tested and shipped (EDG-101, on 2/27/76; E DG-10 2, on 3/27/76; EDG-103, on 5/14/76) before TDI had huplemented the required QA measures.

l

[ _ _ . _ , .

e

', 5. Energy Consultants, Inc. Re po rt. In its final report to the NRC on EDG testing problems at Shoreham, Energy Consul-tants, Inc. reported that a significant number of identified deficiencies " occurred due to errors and incomplete or improp-erly completed work by the manufacturer . . . . [and] vendor workmanship. These errors, in conjunction with the problems identified during audits of Delaval's Quality Assurance Program (audits /reaudits conducted October 1975, February 1976 and June 1976), indicate a weakly implemented Quality Control Program."

(Witness and Evaluation of EDG Testing at Ghoreham Nuclear Power Station for NRC, Final Report, Energy Consultants, Inc.,

/

7/12/83).

IV.D.l. The replacement cylinder heads installed in the EDGs at Shoreham were not designed and manufactured in accor-dance with an effective Appendix B QA program. (NRC I&E Report 83-25, 8/15/83).

2. There is no evidence that the replacement crankshafts (which were not manufactured by TDI) were designed and manufactured in accordance with an effective Appendix B QA pro-gram.

3. The data included in Contention IV and its subparts indicate that TDI never had and does not now have an effective QA program. Accordingly, there can be no adequate confidence

- that the replacement pistons and other replacement components and parts for the EDGs will perform satisfactorily ~in service and will not fail.

IV.E. LILCO's failure to assure that TDI designed the EDGs under an effective Appendix B QA program is demonstrated by the fact that the EDGs were designed and manufactured by TDI during 1974 through 1976 but, contrary to Appendix B, neither LILCO nor its agents conducted any audits to assess TDI's com-pliance with Appendix B, Criterion 3, regarding the design of the EDGs.

G

A ATTACHMENT 1 J

UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION 4

Before the Atomic Safety and Licensing Board

)

In'the Matter of )

)

LONG ISLAND LIGHTING COMFANY ) Docket No. 50-322-OL

)

(Shoreham Nuclear Power Station, )

Unit 1) )

i

)

AFFIDAVIT OF STANLEY G. CHRISTENSEN Stanley G. Christensen, duly sworn, deposes and says as fol-i lows: .

1. My name is Stanley G. Christensen. I am a professor of marine engineering at the United States Merchant-Marine Academy, Kings Point, New York. I am currently one of the expert consul- ,

I tants for Suffolk County, New York. My principal. area of expertise is diesel engines, in which I have been involved for i

over forty years. My experience includes serving as chief engineer in charge of diesel engines in marine applications, and teaching a variety of courses on the design, manufacture, opera- .

tion and repair of diesel engines and their components. I am the author of numerous publications concerning diesel engines, including Lamb's Questions & Answers on the Marine Diesel Engine,

. a standard reference book. My professional qualifications are set  !

forth in more detail in Exhibit A to this Affidavit. I have been ic'n, e'*n', * * - --

S -,

--Ae- - - , -' '- - - -M+

l .

providing services to suffolk County concerning the emergency diesel generators ("EDGs") at the Shoreham plant since June 1983.

2. The purpose of this Affidavit is to explain my technical judgments regarding Suffolk County's proposed supplemental EDG contention I. In reaching these conclusions I have reviewed and analyzed all of the reports and memoranda issued by Failure Analysis Associates concerning EDG parts and components which were made available to Suffolk County, as well as reports by the NRC Staff, documents concerning the EDGs furnished to the County by LILCO, and documents received by the County from owners and operators of other diesel engines manufactured by Transamerica Delaval, Inc. ("Delaval"). I have also visually inspected and taken measurements of certain parts and components of disassembled EDGs, and I have visited Delaval's facility in Oakland, Cali-fornia, inspected the drawing of the Delaval cylinder head, and held discussions with Delaval personnel regarding the cylinder heads. Finally, I have consulted various articles and texts as appropriate.

3. I have conclu,ded that at 4890 horsepower and 3,500 kW, each EDG at Shoreham is over-rated and undersized to meet the operating requirements of FSAR Section 8.3.1.1.5 for continuous operation (8,760 hrs.) at 3,500 kW and overload operation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period at 3,900 kW without reducing the maintenance interval established for the continuous rating.

4. Each EDG is a Delaval model R-48 diesel engine. The Delaval R series diesel engine was developed in the mid-1950's, with an initial rating of approximately 250 horsepower per cyl-

3

, inder. The horsepower of the R series engines was increased to 611 horsepower per cylinder in the EDGs at Shoreham without any fundamental redesign of the engine. Instead, changes were made in the design of particular components. For example, in the late 1960's Delaval introduced the R-4 model (the same model as the Shoreham EDGs) with the current cylinder head design that in-creased the flow of air through the engine; by this change coupled with an increase in operating speed, engine horsepower was boosted without a major overall engine design change.

5. A diesel engine is a complex piece of machinery whose parts are in dynamic inter-relationship. Thus, a change in the design of a major component, such as a cylinder head, a crank-shaft, or a piston, is likely to effect other engine components and, indeed, the performance of the entire engine. In my judg-ment, the piecemeal changes made in the design of particular components of the Delaval engine and other steps taken to more than double the horsepower rating of the R series engine have resulted in an EDG which is over-rated and undersized. For that reason, numerous parts of the Shoreham EDGs were found on dis-assembly to be damaged, and it is likely that additional damage will occur to parts and components with EDG operation at 3,500 kW or higher power: My conclusions are supported by the factors dis-cussed below.

6. I have concluded that the original crankshafts with the 11" pin cracked principally because they were undersized and poorly designed, although my reasons for this conclusion are somewhat~ different from those of Failure Analysis Associates

, ("FaAA"). The standards for crankshaft design in large diesel engines (like the EDGs) used throughout the world by international insurance companies are those of the American Bureau of Shipping, Det Norske Veritas, and Lloyd's Register of Shipping. These standards are more r'ealistic than the voluntary standards of the Diesel Engine Manufacturers Association, an organization composed of six domestic engine manufacturers (including Delaval), whose standards are not approved by the American National Standards Institute or any recognized international standards organization.

FaAA failed to judge the adequacy of the original or of the re-placed crankshafts (with 12" pins) against the internationally recognized standards for crankshaft design.

7. From measurements of the replacement crankshafts and other data concerning their specifications, I have performed the necessary analysis to determine the adequacy of the replacement .

crankshafts under the applicable standards of Lloyd's Register of Shipping. My analysis shows that the replacement crankshafts are inadequate for operation at overload power (10% above 3,500 kW) for periods more than 15 minutes. Beyond that period the crank-shafts can be expected to develop one or more nucleation sites.

While not necessarily visibly evident in the earlier stages of overload, such sites would later cause crankshaft deterioration and possibly failure.

8. My analysis also establishes that even at normal loads up to 3,500 kW, the replacement crankshafts are only of marginal design, with little capacity to safely handle additional potential stresses caused by such factors as unevenness in cylinder firing

~

-5 pressures, or failures of other components such as bearings, cyl-inder heads, or jacket water pumps. Accordingly, one cannot have confidence in the reliability of the replacement crankshafts even when not operating at overload power.

9. The greater weight of the replacement crankshafts and the consequent increase in the whirl created by internal unbal-I anced centrifugal forces acting conjointly on the center main bearing will cause excessive wear on the main bearing between the number 4 and number 5 cylinder. In addition, the effect will loosen the main bearing and cause misalignment of the crankshaft, which could lead to crank" aft failure. While the effect of in-creased crankshaft whirl may be somewhat ameliorated by the fact that Delaval has reduced the weight of the replacement connecting

. rods, that design change might weaken the rods and cause problems in other bearing locations.

10. The cracking of 23 of the 24 pistons in the three EDGs evidences that the pistons were of inadequate design to withstand firing pressures to which they were subjected in the over-rated EDGs, even after a relatively low number of operating hours. This is another indication of the lack of design integration as the series 4 engines were uprated in horsepower. Although I have not yet been able to examine a drawing of the replacement "AE" model Delaval pistons, I have analyzed information regarding their di-mensions and design. My analysis leads to the conclusion that the model "AE" pistons are also of inadequate design to withstand operating conditions. The ratio of the height of the piston skirt relative'to the diameter of the cylinder bore (referred to as the i

,N

. sliding length bore ratio) is t$o low. This indicates that the bearing pressure of the sliding part of the piston skirt will be relatively high, causing overheating which can lead to increased wear on piston rings and to piston shirt cracking. The fastening studs for holding the piston cr'own to the skirt appear to be in-adequate. The. tin plate surface *cf the skirt, while providing some benefit by preventing scuffing of,the skirt, allows dirt to collect and.thereby reduces piston clearance, which leads to over-heating and scoring the Sylinder walls. The position of the piston pin relative :o the piston skirt is undesirably high, pre-sumably to accommodate a. longer connecting rod. This increases the bearing surface pressure on the piston skirt, which leads to overheating that, in turn, may cause the skirt to crack. Finally, i

the "AE" model piston is a new design which is unproven. Its operation, according to Delaval, is limited to testing in an R-5 test engine-and field operation in a single engine. This does not provide, sufficient empirical data to reach positive conclusions about thit ' AE" piston . Piston failure can have adverse conse-i t i

quences on th9 crankshaft and other components, and can degrade EDG performance and even cause engine failure.

11. Cylinder heads installed in the EDGs cracked during operation and were replaced with new cylinder heads of the same

,, design but allegedly superior quality. The design of the cylinder heads is inadequate to withstand the high thermal and mechanical i

The stresses to which'they are subjected during operation.

thickness of the firedeck is uneven. Delaval's design permits thickness variations from as little as .400 inch to as much as t

1, c

r

\

?. . _ . . .

. , _ , _ _ . _ . _ . __a _ . _ , ___ . __

7_

o .881 inch in a firedeck with a nominal specification of .500 inch.

These variations result in increases in either thermal or mechanical stress due to gas pressure, create a stress riser in transition zones, and lead to cracking. The water passages in the cylinder head do not provide for sufficient cooling, which exacerbates the problem of the uneven firedeck. The studs holding the cylinder head in place are not properly spaced, which creates non-uniformity of stress; this again leads to failures in the higher stressed areas.

12. The replacement cylinder heads are not of acceptable manufacturing quality. Of thirteen replacement cylinder heads for the Shoreham EDGs visually inspected by the NRC Staff, one had a crack 3/8 inch long. Delaval nevertheless found the cracked cyl-inder head acceptable because it had passed a nydrostatic test without leaking, and the cracked head was installed.in a Shoreham EDG. See NRC Inspection No. 50-322/83-25. The County's metal-lurical consultant informed me that cracks tend to propagate and grow, and I believe a cylinder head known to be cracked is unac-

~

l l

ceptable for installation in EDGs. Apparently none of the

~

replacement cylinder heads were inspected for cracks by dye penetrant or magnetic particle examination by the NRC or LILCO.

13. Additional cracked heads may be assumed to exist in the EDGs. FaAA reported that .

(C]orrosion of the cylinder liner and I

piston crown was observed in cylinders of two engines . . . .

EDG Crankshaft Failure Investigation, October 31, 1983, at 1-5.

FaAA does not indicate whether it determined the source of the

>, s s

.> f

, corrosion, or the number of cylinders in which corrosion was

. ,e .. .

noted.- No,rrdoes FaAA indicate whether er how it. inspected the cylinder heads in the EDGs for cracks after the crankshaft fail-ure. On the basis of existing evidenca, jacket water in the cylinder resulting from a cracked cylinder hiead may have con-

.. e

, tributed'to the early failure of the undersized and poorly

- i designed crankshaft in EDG 102.

i

~ '

7 g>

14h' Th'e,f oregoinh discussion of certain' major components of -

1.

the EDGs'shows 2 heir interrelationship and,how each is of inade-

. ;r quate design to' sat'isf actorily with' stand th'e operating stresses of the EDGs are their rated power. The weaknesse,s.cf these major

,i -

components may be exacerbated by their inter-relationship with each other

~/ ..

and with 6ther components during operation.

s r

a For ex-

+ ,

j .

ample,-water in the cylinder caused by a cracked cylinder head y +/, - - 7,r c ,.

could adversely impact upon the' pistons and th'e' crankshaft.

1 s .

9 Another example is that a,m$nor failure in the subassembly of the cylinderheadceuldimpaiptheoperationoftheJheadvalves,which

- 3 ,

e in turn coule;overstress the crankshaft.

,t t

• 15..

Additional evidence that t,,he EDGs are.: , ,

+-

>yundersized for 2

their intended functions and over-r.ated is that exhaust tempera- "

! i i o

tures_.in the EDG3 areveryhigb[(aoproximateikl,100degreesF.). . , 1 Further,.the operating experience $f'the D21aval '

diesel engines on

/ . -

t.he Miv. Columbia evidences rinny Tf the smelpp6blems occurred as

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, 'with the Shoreham EDGs; the engines on the Columbia had to be de-rated. Finally, the excessive vibration and variations in vibra-tion levels among the three EDGs may indicate over-rating.

Stanley G. Christensen Subscribed and sworn to before me this day of January, 19 C Notary Public 4

l l

l

t (,,) _

J -

., Exhibit A

?. Stanley G.'Christensen Telephone:

46 Grace Avenue ..

Office: 516-482-8200

, Groat Neck, New York 11021 Ext. 468 7- Home: 516-487-8712 1978 - To Present -

U. S. Merchant Marine Academy, Kings Point, New" York '

Professor of Marine Engineering Director of Continuing Education Program from.1980 Courses Taught Midshipmen: Internal Combustion Engines I & II; '

Diocel Engine Maintenance; Small Vessel Engineering I. & II; Marine Engineering I, II & III; Introduction to Marine Engineering I & II; Marine Refrigeration In Continuing Education, Courses Taught : Medium Speed Diesel Engines; Various Sections in Diesel Propulsion Systems for Marine Engineers ; Fundamentals of Marine Diesel Systems ; Diesel Ship Oparation and Control for Masters and Mates 1977 - 1978 '.

Cova Shipping Inc. , New York, New York Suparintending Engineer managing diesel machinery operations in M.S.C. tankers managed by C, + a Shipping 1973 - 1977 '

Stolt Nielsen Inc. , Greenwich, Connecticut Senior Superintendent Engineer Company owned fleet of diesel propelled tankships Engaged in all aspects of diesel machinery covering design, construction, operation a.nd , repair of diesel machinery and

. support systems 1969 - 1973 -

Scatrain Lines Inc., New York, New York Assistant to V.P. Engineering Covered Company's fleet of foreign flag diesel tankships.

Engaged on constructuon of gas turbine container ships.

Seconded to Seatrain Shipbuilding Corp. to duties in design office. ,

1969 November - Emigrated to U. S. from Europe. ,

1954 te 1969 - o Sugar Line Ltd. , Kentships Ltd. and Associated Companies in Tato & Lyle Group, London, England .

Sugar Line Fleet - 14 diesel bulk carriers 40 plus ships within Group <

Mamber of Board of Directors in various companies in Group.

Chief Superintendent in charge of all ship operating departm'ents.

Directly responsible to Managing Director. Work covered design of new vessels (all diesel). Designed one of the earliest fully automated control diesel ships built in U.K. , designed fi'rst bulk carrier built in U.K. in which alternating current was used.

440V 60 cycle supply. 220V low power and lighting. Year 1958.

Vessel had electrical (AC) cargo winches.

Resigned from Board because of disagreement on Company's policies and emigrated to U. S.

^

Q .

J, ,

3

. l l

tanicy G. Christensen I

l 5 G' race Avenue .

Graat Neck, New York 11021

~.

1950 - 1954 -

Elder De=pster Lines , Liverpool, England -

Floot up to 76 ships .

?crsonal Assistant to Technical Director -

Assistant' Superintendenti Engineer -

Rospensible for new ship design and ' construction. All new ships built diesel propelled.. In charge of all technical investigations '

involving nachinery. ' -

1949 - 1950 i .

Lloyd's ?.egister of Shipping -

, Engineer.. Surveyor in Headquarters en Chief Surveyor's Staff .

'4crked on approval of' machinery design, boiler and pressure vessel d2 sign, stress analysis, investigation of shafting syste=. torsion-al vibration characteristics. ,

1945 - 1949 L3cturer in Marine Engineering

?oplar Technical College, London Taught graduate and post-graduate levels in Strength of Materials,

• The-'sodynamics, Thecry of Machines, Mechanics Static and Dynamics, and Engineering Design.

1935 - 194'5 Served at Sea in Merchant Ships.

So ved from Assistant Engineer up to Chief Engineer.

So ved as Chief Engineer with all classes of machinery including service a.s Chief Engineer in Diesel Ships.

1931 - 1935 Served apprenticeship with Messrs. Earland & violff Shipbuilders sad ::a = %gineers , Lcnd=n and Selfast Edu:ated:

i:altha:s:cw Technical College, Londen

?cpla- Ce:hni:a1 College, L=ndon . .

Inperial College of Science and Technology, London .

Qualifications:

3ritish: Chief Engineers License-Stean- Ships and Motorships

, Unlimited Power and Service j Extra First Class Engineer MOT. United Kingdom I' B. S .. Con:2ecticut State Board United States:

Awards: William Nevins Prize Winner . U.K.

.:.nstitute of Marine Engineer Silver Medallist U. K.

Author: Lamb's Questions and Answers on the Marine Diesel Engine Publisher: Charles Griffin London O -

e

-*y * --~ mere - +r en en - ~ ovrm-,,, t w ,we v- >e-o- r--w e s se e ~ e +-m,-+ wa- ~-ovaa-+- 4-. - + w - = - - am ~ - r- ~

e ATTACHMENT 2 s

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

In the Matter of )

) '

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL

)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

Af?IDAVIT OF GEORGE DENNIS ELEY George Dennis Eley, duly sworn, deposes and says as follows:

1. My name is George Dennis Eley. I am a qualified marine engineer employed by Ocean Fleets Consultancy Services, with offices in Thorofare, New Jersey and New York, New York. My company, a division of Ocean Fleets Ltd., a large European ship-ping fleet operator and part of the Ocean Transport and Trading group, is retained as expert consultants by Suffolk County, New York, with regard to the emergency diesel generators ("EDGs") at the Shoreham Nuclear Power Station. My principal area of exper-tise is diesel engines. My experience includes twelve years service as assistant and as chief engineer in shipc powered by diesel engines. My professional cualifications are set forth in more detail in Exhibit A to this Affidavit. I have been involved through Ocean Fleets in providing services to Suffolk County regarding the EDGs since late December 1983.

) o

. 2: . I have reviewed and analyzed reports and other documents

)- supplied to Suffolk County from Failure Analysis Associates, LILCO, and the NRC Staff regarding the original and replacement crankshafts, pistons and cylinder heads in the EDGs. I have also

) reviewed documents received from the State of Alaska regarding the M.V. Columbia. Finally, I have received certain information concerning measurements of the replacement crankshafts and of

) pistons in the EDGs from Professor Stanley Christensen, and have consulted various articles and texts as appropriate.

3.. I have carefully reviewed the Affidavit of Professor

) Christensen concerning Suffolk County's proposed supplemental EDG Contention I. I am in complete agreement with the statements contained in paragraphs 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14,

) ,

and 15 of Professor Christensen's Affidavit and I adopt such statements as my own, with the following modifications:

a. As to paragraph 7, I obtained certain measurements and

) data concerning the replacement crankshafts from Professor Christensen, but performed an analysis of the adequacy of the replacement crankshafts under the standards of Lloyd's Register of

) Shipping independently of Professor Christensen. While some of the numb'ers in my calculations differ in detail from those of Professor Christensen's analysis, my conclusions are the same.

) b. As to paragraph 12, the County's metallurgical con .

sultant has not discussed crack propagation and growth with me, but I am generally aware that cracks in metal may propagate and

) grow,.especially when the metal is subjected to stress.

)

GP o

c. As to paragraph 15, I have not reviewed vibration data 8 regarding the EDGs and therefore cannot adopt the last sentence.

4 George Dennis Eley

, Subscribed and sworn

-) to before me this day of January, 1984.

Notary Public v

3

Exhibit A CONFIDENTIAL

~

EESHEE Name: George Dennis Eley Address: 117 Bortons Road Marlton, New Jersey 08053 Home Phone: (609) 768-6699 -

Business Phone: (609) 848-2913 Licenses and Certificates: Combined First Class Certificate of Competency Steamship & Motorship. Higher National Certificate in Mechanical Engineering.

Society Memberships: Associate Member of The Institute of Marine Engineers. Member of the Institute of Port Engineers. Member of the ASTM Task Group on Pollution

• Abatement Equipitant (F25.11) .

Employment History 1981 - 1983 Marine Consultant with:-

Dead Office:- Ocean Transport and Trading PLC.

India Buildings Water Street Liverpool, England L20RB Telephone No. 011-44-51-236-9292 Address of U.S.A. Office:-

Ocean Fleets Consultancy Service 1501 Grandview Avenue Midatlantic Corporate Center Thorofare, New Jersey 08086 Telephone Noc. (609) 435-6457 & (609) 848-2913 l

l l

3 Paga 2 1

1969 - 1981: - Third Assistant, 2nd And Chief Marine Engineer with above Company.

1966 - 1969: - Estimator and Contracts Engineer for British shipbuilders at:-

Auptin & Pickersgill Limited shipbuilders and Installation Engineers P.O. Box 38 .

Southwick Sunderland Tyne & Wear, England Telephone Nos. 011-44-783-57684 l

1959 - 1966: - Apprentice Fitter & Turner, then Contracts Engineer with:-

George Clark & N.E.M., LTD.

P.O. Box 8

. Northumberland Engine Works Wallsend, Northumberlan, England Telephone No. 011-44-966-623141 Annwnarv of Work Experience & Accomolisthwents As a Marine Consultant with Ocean Transport & Trading, my duties have included:-

Negotiation and formation of a joint venture with the American Bureau of Shipping to provide fuel services to the marine industry.

My responsibilities have been to negotiate with Senior Officers of ABS and to formulate operational policy. My duties also include coordination of the various departments and efficient operation of the business. I have implemented the Data Bank System for the above business and control the staff so doing. I also act on'an independent consultant on machinery damage investigations and run ceminars for the following establishments on fuel technology.

! 1.) " Kings Point Merchant Marine Academy" on Professor Christenson's " Continuing Education on Diesel Technology" given to chief engineers studying for advanced certification.

Maritime Safety International lecturing to chief and port 2.)

cngineers on poor quality fuel oil.

3.) Marine Engineers Benefit Association to chief and port

cngineers on poor quality fuel oils.

j e

+ - - , - , , ~ , - ~ . -- , . - , , - - - - - - a -- ..--_. ,-,-- , ~ -,---...-

,-_ ,.., _ ,.,.,,.. ,.... .-,-- ,,. n .- - . . , , , - - , . - - . - - . .

. P;ga 3 In addition I advise on system design for ships enginerooms and upgrade existing vessel so that they have full operational capability on lower quality fuel. I have worked in this capacity with major American shipping companies and normally negotiate the contracts for so doing with the vice presidents of those respective companies.

Prior to my employment as a Consultant, I was employed by the same company for 12 years as a tiarine Engineer in all capacities up to the rank of Chief Engineer. In this capacity my responsibilities were for the efficient operation and maintenance of various diesel engines, boilers, air compressors, refrigeration systems.which encompassed a high degree of automation. Coordination with different marine and hull classification societies was also a requirement as was the effective implementation of planned maintenance scheduling.

Before continuing my career at sea, I was employed by British Shipbuilders as a Contracts Engineer. During this period, my responsibilities were to produce ships specifications for newbuildings to a potential owners requirements, and also to handle all ships contract correspondence. It was also my responsibility to estimate the costs of various building projects and submit these costs for negotiation with the-owners representatives. .

Prior to my employment with British Shipbuilders, I served an Engineering Apprenticeship with George Clark & N.E.M. LTD., a Marine Enginebuilder. On completion of my apprenticeship I continued as a Draughtsman with this same company in the Engine Design Department until I was promoted to Contracts Engineer with duties similar to those held at British Shipbuilders.

l

Attcchment 3 e

SUMMARY

OF NRC VENDOR INSPECTION REPORTS NRC INSPECTIONS AT DELAVAL BETWEEN 1979 AND 1983 Defici'encies identified in the development and implementation of the Delaval quality assurance program, as documented in NRC Vendor Inspection Program inspection reports, are summarized as follows:

' Appendix B Criteria Description of Deficiency Violated

1. Contrary to paragraph 2.7.2 of the Quality II Assurance Manual, Revision 11, dated July 6, 1978, procedures manuals had not been established for the Manufacturing and Material Controls Departments. [Rept. 79-01, 3/14/79]

2. Contrary to paragraph 2.7.1 of Section 2 of the V Quality Assurance Manual, dated February 27, 1981, the Quality Assurance / Quality Control Organizational Chart (page 1-10 of Section 1.) had not been updated to reflect changes in the Quality Assurance / Quality Control Organization since January 1, 1982. [Rept.

82-02, 11/24/82]

3. Contrary to paragraph II.3 and 4 of Division STD III.

Practice (DSP) No. 4.101, September 15, 1969, and paragraphs A,4, A,5, and B.1 of DSP No. 4.201, April 15, 1970:

a. Industrial Engineer had not reviewed, approved or disapproved and signed Engineering Change Notice, Control No. 8-92 before drawing had been released to the shop. -

b. The Engineering Change Log had not been main-tained as evidenced by lack of required entries in the " Change Class" and "R Code" columns and changing the " Action Taken" leading to "Cust Job;"

e m

e e

1-

. Appendix B l Criteria Description of Deficiency Violated

c. Accepted requests, Control Nos. 8-42 and 8-217 had I not been classified as major or minor. 1 The originator had not initiated Request for Drawing and Parts List Change, Form No. E-219A, for changes identified on memoranda as Control Nos. 8-19 and 8-60. [Rept. 79-01, 3/14/79)

4. Contrary to paragraphs 5.1.2 and 5.3.3 of Section V 5 of the Quality Assurance Manual dated February 17, 1981: I

a. The component drawing released by engineering did not constitute the final instructions to assembly for definition of acceptance criteria to which the governor lube oil cooler must conform. -

b. Instructions for assembly of governor lube oil cooler to.the engine had not been provided in writing from manufacturing engineering to assembly. .

The foregcing was evidenced by the complete lack of Transamerica Delaval, Incorporated (TDI) documentation for detailed information regarding installation of the governor lube oil cooler onto the engine during the manufacturing / fabrication /

assembly activities. [Rept. 82-02, 11/24/82]

5. Contrary to subparagraphs II.A and II.B dated V January 29, 1976, and November 10, 1969, respectively, of the Drafting Room Practice, the following layout drawings for the late 1982 i redesign of the EDG jacket water pump had not been drawn on tracing paper and signed and dated: (a) 101973, (b) 03-426-08-AA, and (c) 03-425-10-AE (lined through) [Rept. 83-01, 7/27/83]

6. Contrary to paragraphs 2.2 and 2.3 of Engineering V Operating Procedure (EOP) 4 dated April 19, 1979, and paragraph II.A.6 dated January 29, 1976, of the Drafting Room Practice, regarding calculations for the redesign of defective EDG jacket water pumps located at Shoreham Nuclear Power Station:

a. Calculations for the first occurrence (1979), -

which are writtan in the proper notebook, had not been signed and dated in the spaces pro-vided.

w w w w >=__ ,,-,,_. -

n , .- - - - - - - , . - - t - ~ ---,--n, - - - - - - - - ~ - - -

.w . a~ ---

Appendix B Criteria

. Description of Deficiency Violated

b. Calculations for the second occurrence (1982) had not been signed, and written in the proper notebook. (Rept. 83-01, 7/27/83]

7. Contrary to paragraphs 6.1.1, 6.2.1, and 6.3.1 V o'f Section 6 dated February 27, 1981, of the OAM, "D Sheets" which pertain to quality of-the product are issued by the Engineering Department; however, they are not reviewed by the manager as evidenced by the lack of provisions to identify the date, preparer, reviewer, approverf or revision. Exam-pies are D-4986 and D-4956 which are entitled,

" Assembly Instructions," and pertain to the EDG jacket water pump. It was noted that the latter document reflected the release date, four revision levels, and dates in the lower margin of the affected sheets. [Rept, 83-01, 7/27/83).

8. Contrary to Section 7 of the Quality Control V .

Procedure I.P.-700, Quality Engineering did .

not process a Corrective Action Request Form with respect to customer identified failures of TDI to meet weld quality contract requirements in ASME Section III Class 3 diesel generator piping. [Rept. 80-01, 9/16/81]

9. Contrary to paragraph ND-5521(a)(2) and ND-5521 v' -

(e.)(6) in Section III of the ASME Code:

~

a. The TDI written practice (Section 4 of Quality Control Procedure I.P.-600) did

-not describe the procedure used for exami-nation of Level III nondestructive examination personnel.

b. Personnel performing ASME Section III, Sub-section ND and NF, required visual examinations had not been qualified by being subjected to an examination of comparable standard to methods covered by SNT-TC-1A documents.

[Rept. 80-01, 9/16/81].

10. Contrary to paragraphs ND-4321(a-) and ND-4323 in V

Section III of the ASME Code

a. Shielded metal arc welding was observed being performed on a 6 inch Schedule-40 ASME Section III Class 3 piping assembly in the vertical up position, although the welder had been qualified in accordance l

,, -w- - -

---,-,n- - - - - -

, , - , ,_m-.. -,w- en,--,n- -

,w.,gn ,,-m ,,..n, w..gaeve,--wn,mw_.,,,-,-

Appendix B

• Criteria Description of Deficiency Violated with ASME Section IX Code requirements for the

• flat position only. ,

b. Shielded metal are welding was identified to have been performed on a 2 inch ASME Section II Class 3 piping assembly by a welder who had been qualified in accordance with ASME Section IX Code requirements only for pipe I outside diameters of 2 7/8' inch and over.

[Rept. 80-01, 9/16/81]

11. Contrary to Section 5 'foQuality Control Procedure V

,I.P. -500, unused welding electrodes were not being returned to the storage area within four hours of issuance. [Rept. 80-01, 9/16/81]

12. Contrary to Section 4 of Quality Control Procedure V I.P. -500, the space provided on the Route Sheet for welder identification did not allow accom-

. plishment of verification o.f welder use, in that:

a. Welding was observed being performed on two ,

assemblies by different welders to the individuals identified on the Route Sheet.

Alternate records (Weld Reports) for personnel b.

identification had not been prepared for the operations observed. [Rept.. 80-01, 9/16/81]

13. Contrary to Section 10 of the Quality control V Procedure I.P. -500:

a. A defective weld was removed and replaced without rejection and documentation on an Inspection Report,

b. Disposition of a dimensional nonconformance was made by Quality Control Supervision, without submission of the Inspection Report to the Material Review Board for review. [Rept. 80-01, 9/16/81]

14. Contrary to C. F. Braun and Co. Project 4840-P V Specification'164-03, a tank roof to sidewall weld was observed to contain an area with a fillet weld below the size specified by the applicable drawing 02-540-07B7, Revision D. [Rept. 80-01, 9/16/81]

1

(_

• Appendix B

- Criteria

. Description of Deficiency Violated

15. Contrary to Section 4 in Quality Control Procedure V i I.P.-500, performance of required inspections for completed Operation Nos. 10 through 130 on the Production Route Sheet for the Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment could not be verified; in that neither inspection acceptance stamps had been entered for the operations on the production Route Sheet, nor had Inspection Reports been prepared to denote a rejected condition after inspection. [Rept. 80-01,'9/16/81]

16. Contrary to paragraph 5.1.2 of the Quality Assurance V Manual, Revision 0, dated February 27, 1981, the parts list and component drawing released by engineering had not defined the acceptance

> criteria of the installed crankshaft oil plugs.

Further, the route sheet that provided instruction for' installation of the oil plugs contained no acceptance criteria. [Rept. 81-02, 9/15/81]

17. Contrary to paragraph 5.3.2 of the Quality V Assurance Manual, Revision 0, dated February _27, 1981, the instructions at Element C of Operation-

' No. 55-of the Assembly / Test Route Sheet, Revision

! 1, dated June 20, 1981, for Job No. 02933 did not provide details of the swaging operation of the crankshaft oil plugs. [Rept. 81-02, 9/15/81]

18. Contrary to paragraphs 5.3.2, 5.3.3, and 16.2.1 V of Sections 5 and 16, respectively, dated February 27, 1981, of'the QAM, route sheets for the assembly of the EDG jacket water pump reflected on Drawing No. 101973, Revision C, had not been retained by Quality Control as objective evidence by inspec-tion acceptance. [Rept. 83-01, 7/27/83]

i

19. Contrary to paragraphs 2.4.1 and 9.1.1 of Quality V i _ Control Inspection Procedure No. 300 dated April 1, 1981, regarding EDG jacket water pump parts

Appandix B Criteria Description of Deficiency Violated that were manufactured during the time period when defective jacket water pumps were being modified:

a. Stamp and date had not been entered at Operation No. 90 and final accept block of ~

PRS No. 03-426-08-AE water pump shaft which was processed in October 1982. Further, the quantity accepted had not been entered-in the quantity accepted block.

b. Stamp had not been entered in the final accept

, block of PRS No. 101969 seal retainer which ,

was processed in September 1982. [Rept.

83-01, 7/27/83)

20. Contrary to Stone and Webster Engineering Corpora- V tion Specification No. SHI-89 dated June 24, 1981, paragraph 15.3.1 and its subparagraph 5 of EOP 1 dated April 20, 1981, and the

" Qualification Statement for 03-425-04 Jacket Water Cooling Pump Revision" dated October 18, 1982, dynamic analysis or testing had not been conducted on the redesigned ELG jacket water pumps to assure that the seismic qualification had not '

been compromised. [Rept. 83-01, 7/27/83]

21. Contrary to paragraph 9.1.2 of QCM No. 1P-700, VII Revision 1, January 30, 1978; paragraph 6.1.1 of the QSL Procedure, February 3, 1976; and paragraph 5.2.4 of QCM No. QC1, Revision 2, January 30,. 1978:

a. The Qualified Suppliers List (QSL) had'not been updated every three (3) months nor monthly.

The most current QSL exhibited a date of August 24, 1978.

b. A monthly summary of,the quality rating of vendors had not been forwarded to Quality Control and Purchasing. [Rept. 79-01, 3/14/79]

22. Contrary to paragraph 4.7 of Specification No. VII 9645-G-QA-1, Revision 5, dated March 7, 1980 (and previous editions), documentary evidence 9

o Appendix B Criteria o Description of Deficiency Violated was not available to assure that the seller of the motors for the auxiliary lube oil and jacket water pumps had complied with the requirements of the purchase order. [Rept. 81-02, 9/15/81)

23. Contrary to paragraph 4.4.3 of Section 4, dated V February 27, 1981, of the Quality Assurance Manual, Betts Spring Company, a supplier of valve springs (major / critical), had not been surveyed a mi,nimum of once every three years to assure their

- ability to comply with the specification requirements and to review the implementation of.

their quality program. This was evidenced by a Vendor Quality Program Survey (VQPS) form which had been completed February 25, 1976. An updated VQPS was received by TDI on January 27, 1982.-

This form is completed by the vendor and does not assure their ability to comply with specifications or review implementation of their '

quality program. [Rept. 82-01, 3/26/82)

24. Contrary to paragraph 6.1.3 of the Approved v Supplier List (ASL) procedure,. dated ' March 20, 1980, Associated Spring Company (Barnes Group) had been placed on the ASL, dated August 1981, prior to completion of a survey or audit as evidenced by an incomplete Audit Form, dated August 12, 1981. Additionally, a purchase order, dated October 21, 1981, ordered valve springs. [Rept. 82-01, 3/26/82]

25. Contrary to paragraph 4.4.3 of Section 4 of the ". V Quality Assurance Manual, dated February 27, 1981, Kobe Steel Ltd., a supplier of diesel engine cra.nkshafts (major / critical) had not been surveyed at a minimum of once every three years to assure their ability to comply with the specification requirements and to review the implementation of their quality program. A .

survey form completed by Kobe Steel Ltd.'s -

American representative, dated March 8, 1982, was the only indication of a vendor survey record in the Transamerica Delaval supplier's file.

[Rept. 82-02, 11/24/82].

e

___.____.___.___m_ _. "

4 Apptndix B

- - Criteria Description of Deficiency Violated e

26. Contrary to paragraph 4.6.2 of Section 4 of the V Quality Assurance Manual (QAM) and paragraph 4.1.1 of Quality Control Procedure I.P.200, the receiving inspector accepted material on Purchase Order (PO) 45333, for which required mill test reports had not been received, ~

without issuing a nonconformance form P-249

[Rept. 83-01, 7/27/83)

27. Contrary to paragraph A.1 of EOP 7 dated Apr'il V 20, 1981, Purchas'ed Material Specification No.

RL 019000 dated October 6, 1982, had not been approved as evidenced by the lack of a signature in the approval block. [Rept. 83-01, 7/27/83)

28. Contrary to the requirements of Procedure Nos. Not listed 100-W-27, and 100-W-1A, two welders were using unauthorized weld rod sizes. [Rept. 81-01, 9/10/81)

29. Contrary to the requirements of Procedure No. Not listed 100-A-3, a welder failed to turn in unused weld rod within the specified time frame.

[Rept. 81-01, 9/10/81)

30. Contrary to the requirements of Procedure No. Not listed 100-W-18, welding was being done outside the specified electrical parameters. (Rept.

81-01, 9/10/81)

31. Contrary to the requirements of Section 10.0 Not listed of the ASME' accepted QA Manual, affected components listed above in items 28, 29, and 30 were not identified with an inspection report and placed in bond as required.

32. Contrary to paragraph 7.3.1 of Section 7 of the .V QA Manual, a welder was observed welding without the applicable welding procedure being either in his possession, or having been issued in the job package as required by instructions. [Rept. 82-01, 3/26/821

---,,,---y 7 - - - - - .

---ewe-+ g4+$egge s pe ma, - e, y -- -. -

b Appendix B Criteria

$ Description of Deficiency Violated

33. Contrary to Specification 100-A-3 and corrective V action commitments, weld material was not returned to stores within the prescribed time period. [Rept.

82-01, 3/26/82)

34. Contrary to paragraphs 4.11.7, 4.16.4 and 4.53.3 XII of Quality control Manual No. IP-100, Revision 3, January 30, 1978, data had not been recorded for:

i a. Outside Micrometers, S/Ns DTE-001-B, and DTE-014-B, l last recalibrated January 1979, and Pebruary 1979, respectively.

b. Pitch Micrometer, S/N DTE-002J and Thread Micro-meter, S/N DTE-002-AC, both were last recalibrated January 1979.

c. Pressure Gage, S/N DEC-007-AAM, last recalibrated July 1978. [Rept.79-01, 3/14/79)

35. Contrary to paragraphs 10.6.4 and 10.6.5 of Section XII

. 10, June 30, 1979, of the QC Manual, the gage used to measure, accept / reject the diameter and depth of the link rod dowel counterbore had not been identi-fied with: (a) a tool and/or gage tryout tag; (b) a calibration decal; or (c) company name, gage or equip-ment.name, part and/or serial number, as applicable; although the gage has been in use since February 1980.

[Rept. 80-01, 9/16/81)

36. Contrary to Appendix B, measures had not been XII '

established to assure that tools used in the crankshaft oil plug installation are properly controlled and adjusted at specified. periods to I maintain accuracy within necessary limits. [Rept.

l 81-02, 9/15/81)

37. Contrary to paragraph 6.4.5 of QCM No. QCI, XVI Revision 2, January 30, 1978, completed Corrective Action Request activity had not been reported to the Division General manager on a quarterly basis. [Rept. 79-01, 3/14/79]

38. Contrary to paragraph 21.51 of 10 CFR Part 21, Part 21 -

records had not been maintained to indicate that: (a) evaluations had been conducted on the thermostatic control valve, or (b) e I

- . , . _ , , .- --,..w-- . ,e,v ,r,.,,,,-.,--- ..---..-r . , - - .--m.-,-,-----=*-,y ,--

4 Appendix B Criteria Description of Deficiency Violated a

~

corrective action had been planned.or taken regarding other possible locations / users of thermostatic control valves with raised face flanges; excluding Grand Gulf. [Rept. 80-01, ,

9/16/81]

39. Contrary to Section 21.21(b)(1) of 10 CFR Part Part 21 21 dated December 30, 1982, a director, responsible officer, or designated person had not notified the NRC in regard to:

a. Jacket water pump shaft failures on EDGs -

that had been furnished to Shoreham,

b. A potential defect in the fuel injection line tubing that was used on EDGs furnished to Grand Gulf and San Onofre. [Rept. 83-01, 7/27/83]

40. Contrary to the commitment date of July 15, 1982 in V TDI's 10 CFR Part 21 report dated June 23, 1982 concerning unqualified material in flexible drive couplings of 'EDGs, the notification letters were not sent until August 18, 1982. [Rept. 83-01, 7/27/83]

41. Contrary t paragraph 16.7.1 of QAM, Revision XVII 11, July 6, 1978, records in the Document Control Center had not been protected against fire inasmuch as they occupy 10/5 drawer and 1/4 drawer file cabinets.' The latter is the only one fire-rated-350*F for'one hour. [Rept. 79-01, 3/14/79]

42. Contrary to paragraph 4.17.1 of Specification No. XVII 9645-G-QA-1, Revision 5, dated March 1980 (and previous editions), records had not been maintained to furnish evidence that the motors for the auxiliary lube oil and jacket water pumps had been environmentally qualified. [Rept. 81-01, 9/15/81]

43. Contrary to paragraph 16.7.1 of the QA Manual, QA V Manual, QA Records were not being protected against fire, damage or loss. [Rept. 82-01, 3/26/82) d

4

• Appendix B Criteria Description of Deficiency Violated

44. Contrary to paragraph 17.1.1 of the QAM, Revision 11, XVIII July 6, 1978, audits had not been performed semi-annually for the Foundry, Manufacturing,

, and Support activities. Records indicated audits had been performed as follows: Foundry, March 14, 1977; Manufacturing, June 24,. 1977, and May 31, 1978; and support, August 15, 1977. [Rept. 79-01, 3/14/79]

45. Contrary to TDI commitment as stated in its V letter of June 5, 1981, to NRC, the audit of the ASME Weld Shop had not been performed as committed.

[Rept. 82-01, 3/26/82) o e

I v- - y ,e,,s.,--o-e,- , -+, r,ws,~~~~- y - --

ANNEX B 4

DOCK ~TED UNITED STATES OF AMERICA DI y~

. NUCLEAR REGULATORY COMMISSION .

ATOMIC SAFETY AND LICENSING B0 RD Pl2:56 Before Administrative Judgef,[Ei.E C;~ 5.i'.F;. .

Peter B. Bloch , Chai man ~"~ 3"9,..'

~i -

Dr. Jerry R. Kline Mr. Glenn O. Bright , j g n z .g g In the Matter of Docket Nos. 50-440-OL 50-441-OL CLEVELAND ELECTRIC ILLUMINATING COMPANY: et al.

(Perry Nuclear Power Plant, Units 1 & 2) December 23, 1983 MEMORANDUM AND ORDER (New Contention on Diesel Generators)

Ohio Citizens for Responsible Energy's (OCRE's) September 26, 1983 Motion to Resubmit its Contention #2 (Motion) shall be granted. Howev-er, our review of the basis for the contention persuades us that it should be siinplifiedl and admitted into this proceeding in the following -

fom:

Issue # 16. Applicant has not demonstrated that it can reli-ably generate emergency on-sito p # by relying on four

. Transamerica Delaval diesel generators, two for each of its Perry units.

Although this contention no longer states that a third, indepen-dently manufactured diesel generator must be ordered for each of the Perry units, as the submitted contention did state, OCRE will have the opportunity to establish the validity of its contention and to demon-strate what' relief may be appropriate, including the addition. of a third 1

The CFR iauthority).to 2.714(e simplify and focus contentions is derived from 10

Diesel Generator: 2 1

i diesel generator. However, Cleveland Electrical Illuminating Co. , n al. (applicant) will be permitted either to demonstrate the invalidity of the contention or that OCRE's concerns have been resolved by appro-l priate action, in compliance with 10 CFR, Part 50, Appendix B, General Design Criterion 17 and applicable guidance.

I. BASIS FOR THE CONTENTION Although this contention must meet the five criteria of 10 CFR I 2.714(a)(1) before it is entitled to substantive consideration,2 we find it useful to discuss DCRE's basis for the contention before we address the late-filing criteria.

The event which triggered the filing of OCRE's motion was the August 12, 1983, failure --ciuring a load test-- of the main crankshaft of the #102 Electrical Diesel Generator of the Shoreham Nuclear Power Station. That event was followed by an inspection of the crankshafts on 2 We need not decide the merits of OCRE's argument that we should admit this contention because applicant obtained dismissal of its Contention 2 (which it is resubmitting) by a misstatement.

However, applicant did not conceal any facts. Although its argument may have been somewhat misleading, OCRE had all the information available to it during the special prehearing conference that it has now, since it relies for this argument on FSAR 5 8.3.1.1.3.2. OCRE's Motion at 2. We note that the key question for availability of on-site power is whether Perry can achieve safe shutdown. Compare OCRE's Motion at 2 to NRC Staff Response to OCRE Motion to Resubmit Rejected Proposed Contentior. 2, October 6, 1983 (Staff Response) at 4, citing SER ll 8.3.1 and 9.6.3. (Our record is not clear on whether applicant can rely on its High Pressure Core Spray dedicated diesel generators to achieve

-safe shutdown, even if both the larger diesels are unavailable.)

l

q Diesel Generator: 3 the #101 and #103 Electrical Diesel Generators, and each of these was found to have " cracks in locations similar to that of the break in the

1. 102 trankshaft." All three electrical diesel generators at Shoreham were supplied by Transamerica Delaval.3 OCRE's Motion does not rely entirely on these remarkable events at Shoreham. It relies as well on reported deficiencies in Perry diesel generators, which also are manufactured by Transamerica Delaval. It states that the 11 deficiencies are " harbingers of troubles to come."4 Applicant correctly states that the mere listing of deficiencies does not provide a basis for a contention, since the reporting of deficiencies may merely indicate the correct operation of a quality assurance system'.5 .However, the Nuclear Regulatory Comission's Staff (staff) has concluded that the crankshaft failure end "many minor ,

problems" in Transamerica Delaval generators constitutes an "abnomally high" rate of problems.6 It also is concerned about the adequacy of the 3

Staff Response, Attachment E, " Summa ry of September 2, 1983 Emergency Diesel Generator Meeting," September 21, 1983 at 1.

OCRE's, Motion at 4 (footnote 1 re-coritinued).

5 LBP-81-24, 14 NRC 175 at 211. Applicants' Answer to Ohio Citizens for Responsible Energy Motion to Resubmit its Contention #2, October 3, 1983 (Applicant's Answer).

6 Eisenhut, "New Information Concerning Transamerica Da rrell G.

Delaval (TDI) Emergency Diesel Generators , Board Notification 83-160," October 21, 1983 (Board Notification) at 1.

Diesel Generator: 4 quality assurance program of Transamerica Delaval,7 and has changed its conclusion about the adequacy of the basis for OCRE's contention, currently concluding that it has a basis.O Furthermore, we note that a number of the problems in Perry's generators appear to be related to design problems. Deficiency Analysis Report (DAR) 044 concerned a problem in the design of the system for lubricating the turbocharger thrust bearings.9 DAR 079 involved poten-tial leakage of a check valve in a seismic event, and we are unable to tell from the DAR whether a design problem occurred. DAR 081 is a design problem, the choice of a mounting location for the governor lube oil cooler. DAR 083 concerns " inadequate Code Data Reports," and we are unable to tell from the DAR whether or not this may indicate a lack of thoroughness in Transamerica Delaval's application of Code provisions.

DAR 089 concerns nonconforming piping welds, but the DAR does not disclose whether this was a design problem or a manufacturing problem.

DAR 099 may have resulted from a failure by the designer to consider the clearance that would be necessary for proper installation of a cap screw. DAR 101 may have been caused by improper choice of a material.

7 Id. at 2. See also id. at Enclosure 5 (letter transmitting Notice oT Violation).

8 NRC Staff Supplemental Response (Based Upon New Information in Board Notification BN-83-160), October 27, 1983 at 2, 2-3.

9 For a discussion of these DARs, see Applicant's Answer at 12-14 and the referenced attachments.

i

/

Diesel Generator: 5 DAR 109 may have occurred because of an improper or incomplete specification of the grade of electrical wiring. DAR 117 apparently resulted from a design failure to comply with the ASME Code previsions

. governing pipe supports. DAR 139 invcives a possible failure to use Class 1E power as required by the regulations.

We note that the serious failure at Shoreham also involved improper design of the crankshafts.10 We do not consider it appropriate to consider at this time affirma-tive defenses raised by applicant in affidavits. Whether or not appli-cant's quality assurance program has been adequate to detect design or manufacturing problems in the Delaval generators is a matter to decide after discovery has occurred, not before. Furthennore, we do not even have a description of how applicant has attempted to assure the quality of the design of the Delaval generators.

We conclude that OCRE has set forth the basis for its contention with sufficient specificity to gain admission of this issue to the proceeding.

l II. Good Cause for Late Filing After consideration of each of the five factors set forth in 10 CFR i 2.714(a)('1), we find tnat the balance of these factors weighs in favor 10 Applicant's Answer to "NRC Staff Supplemental Response", December 16,1983 (Turk /Swansiger Affidavit at 115-6).

l

-; s Diesel Generator: 6

.. t of the admission of OCRE's contention.

,t OCRE filed shortly after the Shoreham incident, which is the kind s

of event that brings a potential problem graphically to mind and causes wise people to rethink their positicns. The event has had that effect on both the staff and on OCRE. The fact that other parts of the jigsaw puzzi of inadequate quality assurance were previously available does not detract from the significance of this new information. OCRE had good cause for late filing.

We find that the second and fourth factors, considered together, also favor OCRE's contention. The Appeal Board recently cartigated counsel for another applicant for an unbalanced presentation of an

' argument that the staffT cou)d adequately represent an intervenor's i

'l interest.11 In its decision,.the' Appeal Board said:

The annals of NRC .acjudNations reflect that the position taken by staff en a specific safety or environmental issue (in the fulfillmenti of i lts role as the pmtector of the general public interest) often is at odds with the views espoused by an intervenor seedng to vindicate either its personal inter-est or its independent perception respecting where the public interest lies. Indeed, it was doubtless in recognition of the potential for such divergence that the Congress elected to provide hearing rights . to private citizens and organizations in Section 189 42U.S.C.2239.ftheAtcmicEnergyActof1954,asamended,

\

s 11 Washington Public Power Supply System, et al . , ALAB-747, 18 NRC (November 15, 1983), slip op. at 9-1 E 12 Se's i)so, footnote 25, 18 NRC Id at 13-14. at , slip oo. at TE, "[I]n cases wiiere there are no other intervenors, the Tolirth factor may always favor a grant of a late intervention petition."

s

l Diesel Generator: 7 )

We note that applicant's rather novel suggestion that it can adequately represent OCRE's interests was unsupported by authority. We consider this argument to fall a fortiori because of the just-referenced authority that the staff, which is responsible for serving the public interest, cannot adequately represent OCRE.13 The third factor, the extent to which OCRE may be expected to participate in the development of a sound record, weighs in OCRE's favor. In this instance, OCRE has laid before the Board evidence suggestive of a pattern of design deficiencies. Had this evidence not been brought to us, we would have remained ignorant nf the problem.

Furthermore, OCRE reached a plausible conclusion about the implications of the Shoreham incident, based on a reasonable interpretation of available evidence, before the staff reached that same conclusion. This represents considerable sophistication and diligence. We recognize that OCRE's greatest drawback as a party is that it has not yet presented any l

witnesses to this Board and has not made any promises to do so on this i

i issue. This represents a weakness with respect to the third factor, but not a fatal one --particularly because the staff position makes it 13 The staff's argument, Staff Response at 18 NRC at , sli op. at 7-9, was addressed directly by the Appeal T5srd in tne case, cited above, and we find it to be entirely without merit.

) t l g l .. Diesel Generator: E I

", j; j '

likely that there may be some divergence of opinion that OCRE may help

- to develop for the Board.14 The fifth factor, broadening the issues or delaying the proceeding, works mildly agains.t admission of this contention. To mitigate the risk of delay of the proceeding , the Board adopts the following filing schedule:

1. Briefs on the regulations and guidance applicable to this issue will be simultaneously filed by January 20, 1984, with replies permitted by February 3,1984. Service of the brief, but not the reply, should be by express mail.

2. The last discovery reques',, subject to good cause for an extension of time or for late filing, must be made by April 6, 1984. Parties should conduct discovery so that all follow- .

up interrogatories may be filed by that target date.

In light of these actions, designed to manage this phase of the proceed-ing, the effect of the broadening of the issues and the potential for delay is expected to be minimal.

ORDER For all the foregoing reasons and based on consideration of the entire record in this matter, it is this 23rd day of December 1983 14 We do not interpret WPpSS, supra, to require an intervenor to indicate testimony it T present if it has established'fts ability to contribute to the record in other we.ys. See the concurring opinion of Mr. Edles at 18 NRC , , slip op. at 28-30. - -

t l Diesel Generatdr: 9 ORDERED:

Issue # 16, concerning the reliability of generators supplied by Transamerica Delaval, shall be admitted into this proceeding. The schedule discussed in the memorandum for the filing of briefs and completion of discovery is hereby adopted.

THE ATOMIC SAFETY AND LICENSING BOARD .

' Peter B. Bloch, Chairman ,

ADMINISTRATIVE JUDGE

~

,(*

]perrymR. Kline R/M a ADMINISTRATIVE JUDGE M -- 8 b . M Glenn 0. Bright /

I ADMINISTRATIVE JUDGE l

Bethesda, Maryland l -

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Annax C, Exhibit A t

COMPIDENTIAL

• EEEut15 Name: Thomas A. Moore Address: 5 East Red Oak Drive Voorhees, New Jersey 08043 Telephone No. Home: 609-424-8259 Business: 609-848-2913 work Ernerience ,

Msy 1982-Present General Manager Ocean Fleets Services Thorofare, New Jersey 08086 Jan. 1980-May 1982 Research & Development Ocean Fleets LTD.

Liverpool., England Responsible for development of Ocean Fleets Fuel Conservation Program, which included developing an Onboard Testing Kit for Fuel Oil Properties, now used by both major American and European shipowners. .Also initiated, planned and organized Fuel Quality Seminars for the companies senior sea staff, and investigations into diesel engine failures.

Aug. 1968-Dec. 1979 Served as Chief Engineer on Ocean Fleets vessels, responsible for management and the operation of vessels main and auxiliary machinery on diesel and steam driven vessels.

Aug. 1961-July 1968 Served as Third and Second Engineer on Ocean Fleets ocean going vessels.

1 i

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• Resume - T. A. Moore Dec. 1959-July 1961 Shell Chemical Company Carrington (Nr. Manchester), England Process Foreman on Chemical Plant Responsible for day-to-day operation,of fractionating column producing various distillates. ,

Har. 1957-Nov. 1959 Cunard Steamship Company i Liverpool, England l Served as Seagoing Engineer on ocean going '

liners including Queen Mary and the Queen Elizabeth.

Jan 1953-Feb. 1957 T. & J. Harrison Liverpool, England Served as Seagoing Engineer on ocean going vessels attaining the rank of Second Engineer.

Sept. 1947-Dec. 1952 C. % H. Crichton,' Ship Repairers Liverpool, England Apprenticed as Marine Fitter and Turner SOCIETY ME!3ERSHIPS Member of Society of Naval Architects and Marine Engineers Member of New York Society of Port Engineers Associate Menber of Institute of Marine Engineers i

TECHNICAL PAPERS I

" Energy Conservation By Seastaff: presented at Institute of Marine Engineers - Mark Lane, London at Conference on Fuel Priorities February, 1982. And also at Society of Port Engineer, New York on September 14, 1982, l

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, Page 3

. Resume - T. A. Moore "A Ship Operatiors Experience in Monitoring Fuel Quality and Devising Means of Coping with It" - presented at Ship Repair and Maintenance 82 Conference on June 1982, New Orleans. And also at {

31st Annual Fort Schuyler Forum, New York on March 1983.

LICENSES Combined First Clac; Certificate of Competency Steamship &

Motorship.

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Annax C, Exhibit B RESUME 1 ANIESH BAKSE--' Phone (B) 201-343-3335 E10h ox _ sun Drive g -

(H) 609-799-5633 O'ainsboro, N.J. Oo336.

PERSONAL Age - 30 Yrs... Height - 3'11", Weight - 164 Lbs.

EMPLOV' TENT 1982 - 1983 MARINE SURVEYOR AND TECHNICAL CCNSULTANT.

T.J.D. Enterprises, N. Jersey.

National Marine Consultants, N. Jersey.

1978 - 1981 CHIEF EIGINEER/ PORT ENGHTEIR.

Arya National Shipping Lines, LONDON, U.K.

1977 - 1978 SECOND DiGDim/ ASSISTANT PROJECT E!GINIER. 1 Kapal Management Pvt.Ltd., SINGAPORE (KEPPEL SHIPYARIl 1974. - 1977 THIRD ENGINEER. -

Scindia Steam and Navigation Co.Ltd .. BOMSAY 1969 - 1973 ENGINEER APPRENTICE Scindia. Shipyard, BOM3AT.

SUMMARY

OF WORK EXPERIENCE & ACCOMPLISEMENTS As marine , surveyor and techn2. cal consultant,. duties include coordinating various machinery repairs and out hull and cargo surveys As chief carrying engineer / port engineer worked on ve.rious diesel engines, boiler, . air compression and rsfrigeration systems . encompassing a high degree of. automation.

Responsible for the overation, maintenance and subsequent reports of'all nachiner r Monitored all paper work relating to the engine and personnel.

Introduced a cost-effective planned saintenance and inventory control system. In view of.my strong analytieel r nd professione.1 akd' 4 64 a=, prc=cted as the youngast chief engineer in the company Shipyard experience includes, incharre of dry-deck repairs and supervision of new ccustruction with an emphasis in the piping design and non-destructive testing departments. Also coord N ted with differcst marine and hull classification societics dul-ing pla.n approval and surveys..

EDUCATION .

1982 STATE Uru.vt x5ITY OF NEW YORK, MARITIME COLLEGE,. N.Y.

M,,5., in Marine Transportation Management 1978 SOUTE SHIELDS MARINE & TICENICAL Cor m E, U.g.

B.S in Marine En52.neering (Chief Engineer's Licensel :

f MARINE ENGIhr r x.u,3 TECHNICAL COLLEGI, BOMBAY.

1969 - 1972.

1968 HIGE SCEOOL, 'O' LEVELS, UE!VERSITY OF CAMERIDGE, U I.

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!- WODK EXpIFIENCE a'

1982 - 1983 T.J.D. Enterprises, N. Jersey.

. National Marine Censultants, N. Jersey.

Presently working as =arine surveyor and technical <

consultant. Work includes inspection and survey of hull, cargo and =achinery. Also interface i i machinery repairs between ship and shore.

Responsibilities also encompass carrying out various feasibility studies for machinery performance

• monitoring systems. ',

1977 - 1981 Arya National Shipping Lines, LONDON.  :

Kapal Management pvt.Ltd., SINGAPORE (KZpFEL SEIpYARDf SHIPYARD AND ADMINISTRATIVE EXPERIENCE E= ployed as chief engineer and certified for =otor v-asels of any horse power. Steam generation experience includes operation, maintenance and survey of different low and high pressure boilers and related machinery - some of them being Babcock

& Wilcox, Scotch and Cochran type boilers.

The ships worked on were semi to fully automated.

I was responsible for the supervision of eleven .

people in the engine room. All repairs were effected on board, a result of tact and effective dealing with the various union crew.

. Repairs normally could be underlined as overhaul l

of main and auxiliary engine units, air compressors, '

an* W7 pumps and pumping systems. Also was responsible for the efficient runn4 ng and maintenance of the air conditioning and freon and ammonia refrigeration plants.

In the shipyard was incharge of complete dry-dock repairs including propeller and tail end shaft removal and inspection. Also supervised construction of mini-bulk carriers. Work *d in '

the piping design and plan approval departments.

Coordinated with different classification societies for annual and five yearly surveys. Was authorized to certify machinery for fulfilling insurance requirements for various classification societies.

As port / chief engineer monitored all paper work relating to the operation of the boilers and engines such as oil consumption, indenting spare parts, perfor=ance reports, sea voyage and final anal ysis reports. -

REFERENCES Available on request.

DN [ g w/n );.

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Annex C, Exhibit C i

k BIOGRAPHICAL DATA NAME: Robert Neil Anderson .

ADDRESS:

• Work: Department of Materials Engineerin9 San Jose State University San Jose, California 95192 (408/277-3751 or 277-2446)

Home: 3084 Stelling Drive Palo Alto, California 94303' (415/494-7824)

PERSONAL INFORMATION:

Date of Birth: November 8, 1933 Place of Birth: San Jose Marital Status: Married; two children EDUCATION .

B.'S. , Chemistry University of San Francisco,1955 B.S. , Chemical Engineering, University of California - Berkeley.1958

. M.S., Chemical Engineering, University of California - Berkeley 1959 Ph.D. , Metallurgy, Stanford University,1969 Post Doctoral Study in Metallurgy - Stanford University, 1970-1973 PROFESSIONAL EXPERIENCE:

Academic:

San Jose State University, Professor 1978 - Current San Jose State University, Associate Professor, 1974-78 Stanford University, Associate Professor, 1973-74 Stanford University, Research rietallurgist, 1972-73 .

Stanford University, Post Doctoral Research Associate, 1970-72 University of California, Berkeley, Research Assistant, 1958-59 University of San Francisco, Chemist, 1955-56 Industrial:

U.S. Naval Radiological Defense Laboratory, Operations Research Analyst, 1966-69 U.S. Naval Padiological Defense Laboratory, Research Engineer, 1959-66 Arabian American Oil Company, Chemist, 1954-55 l

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PROFESSIONAL EXPERIENCE (continued)

Consulting:

California Public Utilities, Comission,1979 Standard Oil Company of Indiana,1978 - present Lawrence Livermore Laboratory,1978 - present

• Radiological Science Inc., 1977 - present California State Energy, Resources and Development Comission, 1977-79 Executive Office of the President of the United States Council on Environmental Quality and Office of Science and Technology Policy, 1978 United States Congress, Office' of Technology Assessment,1979 Scientific Sarvice Incorporated, 1977-78 MHB Associates, 1977 - present Parlee-Anderson Corp. ,1979 - present .

Accident Analysis, 1974 - present l McDemitt Mine,1976 - present International Business Machines, 1977-78 Memorex, 1979 Electrical Power Research Institute,1974 ,

SRI, 1975-77 Brookhaven National Laboratories,.1977-78 Attornies (11st on request)

PROFESSIONAL ACTIVITIES:

American Nuclear Society, American Institute of Chemical Engineers, American Chemical Society, American Institute of Metallurgical Engineers (Past Chaiman oY Northern California Section),

American Society of Metals, National Society for Professional i

Engineers, American Society for Engineering Education, California Academy of Science, Alpha Chi Sigma, Tau Beta Pi and Sigma Xi.

CREDENTIALS AND LICENSES:

California Standard Teaching Credential.

Registered Metallurgical Engineer, California. . .

Registered Nuclear Engineer, California.

. Fallout Shelter Analyst.

Private Pilots License.

PUBLICATIONS:

Articles : .

l 1. "The Activity of Titanium in Liquid Alloys," Accepted fer publication and presentation in the Fourth International Conference on Titanium 19-22 Mcy,1980, International Conference Hall, Kyoto, Japan.

2. " Internationally Safeguarded Atomic Fuel Exchange Center for the Asia-Pacific Basin," Proceedings in 2nd Miami International Conference

^

O . )

't PUBLICATIONS (continued) on Alternative Energy Sources,10-13 December 1979, Miami Beach, Florida.

3. " Site Selection for Spent Fuel Storage Facilities in the Pacific Basin,"

Nuclear Engineering International, October,1979.

4. " Survey of Nuclear Fuel Reprocessing Technologies," Conservation and 1 l

Recycling, October,1979. '

5. The Gold Dagger of Tutankhamun, Grafico Publishing Co. , Santa Clara, Ca., 1979 (available through the San Francisco De Young Museum).

6. " Analysis of the Infrastructure of the Front End of the Uranium Fuel Cycle," San Jose State University, Materials Engineering Department, technical report prepared for the California Public Utilities Comission (August.30,1979).

7. "The Kinetics of UO2 Reduction by Carbon in Liquid Tin," Lawrence Livemore Lab Technical Report, July,1979.

8. " Analysis of the Front End of the Uranium Fuel Cycle Including Uranium Resource Availability through the Year 2010," San Jose State University, Materials Engineering Department, report prepared for the California Public Utilities Commission (July 1,1979).

9. "The Mineral Industries and the Challenges of the 80's," paper presented to the Pacific Southwest' Minerals Conference, San Francisco March 25, 1979.

10. "The Effect of Equipment Design, Operational Parameters and Surface l Condit13ns on Coatings Produced by Flame Spraying," Journal of Thin Solid Films, accepted for publication 1979.

11. "The Effect of Pressure on Interface Interactions Between Solids,"

Proceedings of the Conference on High-Level Radioactive Solid Waste l Forms 19-21 December 1978, Denver, Colorado. .

12. "Let's Use MHD to Smelt Metals: Industrial Research/ Development September 1978 (p.p.131-34).

13. "The Application of M69neto Hydro-Dynamics to Steelmaking," Industrial Research and Development, September,1978.

14. " Cleaning and Surface Preparation Technology and Other Factors on Coatings Produced by Flame Spraying," presented at the 4th International

' Symposium on Contamination Control,10-13 September 1978, Washington, D.C.

15. " Separation Technologies Reviewed," Nuclear Engineering International, August, 1978.

O u O- . O

, PUBLICATIONS (continued)

, 16. " Spent Fuel Disposal Costs," report to the Natural Resources Defense

? Council, July, 1978.

17. " Examinations of Radioactivity and Environmental Aspects of Antartic Soils at Point Hueneme," report to the California Solid Waste Board, July, 1978.

18. Invited contributor to the Executive Office of the President of the United States document on Nuclear Power and Nuclear Waste Disposal for the President of the United States, June, 1978.

19. " Technical Review of the Deutch Draft Report on Nuclear Waste Management," for the Council on Environmental Quality, Executive Office of the Presi-dent of the Unites States, May, 1978.

20. "A Technical Assessment cf Nuclear Fuel Reprocessing and Radioactive Waste Disposal," report to State of California Energy Resources Conservation and Development Commission, March, 1978.

21. "A Program Assessment of Nuclear Fuel Reprocessing and Radioactive Waste Disposal," report to State of California Energy Resources Conservation and Development Comission, January,1978.

22. " Methodology for Comparative Evaluation of Nuclear Fuel Reproce'ssing Techniques for Advanced Low Proliferation Risks," Proceedings of the First International Conference on Alternative Energy. Sources, December,1977, Coral Gables , Florida.

23. "Hydrometallurgical Separation of the Zinc-Base Fraction of Shredded Automobiles ," Conservatieri and Recycling, V.1,1977,

24. " Survey of Reprocessing Technologies," Brookhaven National Leboratories Report 23082, June, 1977.

- 25. The Physical & Chemical Characteristics of Titanium-Copper Alloys,"

Technical Report to Regalware, July, 1977.

26. "A Methodology for Evaluation of Alternative Technologies Applied to Nuclear Fuel Reprocessing," Brookhaven National Laboratory Report 50700, July, 1977.

27. " Comparative Evaluation of Nuclear Fuel Reprocessing Techniques for Advanced Fuel Cycle Concepts," report prepared for Brookhaven Nationc e .

Laboratory, September, 1976.

28. " Meet the ANF Reactor," Industrial Research May, 1976.

29. "A Technical and Economic Analysis of Processes for the Recovery of Metals in the Non-Ferrous Portion of Automobile Shredder Refuse,"

Proceedings of the Fifth Mineral Waste Utilization Symposium, April 13-14, 1976.

e n -

Q. - r) i PUBLICATIONS (continued) ,

' 30. " Evaluation of Mineral Wasts Utilization Processes and Strategies by Net Energy Analysis ," Proceedings of the Fif th Mineral Waste Utilization Symposium, April 13-14, 1976.

31.

"Available Supply of Gallium and Arsenic," prepared for NASA Langley Research Center, Va., April 1976.

32.

"Carbothermic Reduction of Refractory Metals " J. of Vacuum Science

& Technology, V. 13 No. 1, Jan/Feb 1976; " Nuclear Plant C Gold," San Jose News, March San Jose News, 1975. 4 33.

" Thermodynamics of Nitride Fomation in Liquid U-Gd-Sn Alloys,"

Journal of High Temperature Science, V. 7,1975.

34. " Study of Interdiffusion in Electroplated Si-H1 on Au," Solid State Technology November 1974.

35.

" Nitrogen Nitride Equilibria in Molten Y-Sn Alloys, " Journal of High Temperature Science, V. 6,1974.

36.

"The Kinetics of Uranium Nitride Fomation in U-Sn Alloys," Journal of High Temperature Science, V. 6,1974.

37.

"Themodynamics of Nitride Formation in Liquid U-Gd-Sn Alloys,"

Journal of High Temperature Science, Abstract in Journal of Metal, January, 1974.

38. " Nitrogen-Mitride Equilibria in Molten Y-Sn Alloys," Submitted to the Journal of High Temperature Science, -(with A-FUWA and N.A.D. Pa 39.

"The Kinetics of Uranium Nitride Formatio'n om liquid U-Sn Alloys,"

submitted to Metallurgical Transactions (with T. Sc ~

40. Application of S.'lution Thermodynamics in High Temperature M Processes, Proc. of 67th Meeting of the American Institute of Chemic Engineers, Dec. 1-15, 1974.

41. " Nitrogen-Mitride Equilibria in Molten Pr-Sn Alloys," Journal of 1973.

High Temperature Science, V. 5,

42. " Nitrogen-Nitride Equilibria in Molten Gd-Sn Alloys," Journal of High Temperature Science,' V. 5, 1973.

43. " Nitrogen-Nitride Equilibria in Molten Gd-Sn Alloys," , Journal of High Temperature Science, V. 5,1973. ,

44.

" Continuous Removal of Fission Products in a Nitride Fueled Reac Nuclear Technology, V.13, March 1972 (297-300).

i - . _ - .. . ..

4, PUB}! CATIONS (continued)

>g 45, " Application of Nitride-Forming Reactions to Reprocessing of A Spent Nuclear Fuels ," Nuclear Technology, V.13, January,1972.

46, " Reassessment of the Copper-Boron Phase Diagram," Journal of the Less Comon Metals , V. 25, December 1971 (427-430).

~

47, " Nitrogen-Nitride Reactions in Molten U-Sn Alloys," TMS-AIME Metallurgical Transactions, V. 2., June, 1971

48. " Standard Free Energy of Nitride Formation From the Elements, A Estimation Technique," Journal of High Temperature Science, V. 2, 1970.

49. " Ultrasonic Decontamination of Military Weapons," NRA Riflemen, November, 1963.

50. "The Contamination-Decontamination of Fission Products in Sea Water," Nuclear Detonations and Marine Radioactivity Symposium, yeller, Norway,1963.

51. "Two Phase Heat Transfer," Industrial and Engineering Chemistry, V, 51, 1959..

PATENTS ISSUED IN THE FIELD OF MATERIALS SCIENCE:

U.S. Patents 3,794,482 Feb. 26, 1974 3,843,765 Oct, 22, 1974 3,843,766 Oct. 22, 1974

. Canadian Patents 931,672 Aug. 7, 1973 931,673 .Aug. 7, 1973 950,683 Juiy 9, 1974 Great Britain 1,342,991 Jan. 18, 1971 1,344,950 Jan. 18, 1971 1,323,474 Nov. 13,1970 1,323,475 Nov. 13, 1970 -

Mexico 119,105 Jan. 30, 1971 How Zealand 163,527 Jan. 15, 1971 Sou% Africa 71/0273 Jan. 18, 1971 Sweden 1166/71 Feb. 1, 1971 W. Germany 2,103,255 Jan. 25, 1971 U.S. Patent Applications 905,745 filed May 15, 1978 038,382 filed May 14, 1979 i '

_ _ _ _ _ _ _ . _ . _ . _ _