ML20080B674
| ML20080B674 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/03/1984 |
| From: | Swiger M CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8402070233 | |
| Download: ML20080B674 (18) | |
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i 00CKETED USNRC Februaryg, 8
UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
APPLICANTS' REPLY TO NRC STAFF AND OHIO CITIZENS FOR RESPONSIBLE ENERGY
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BRIEFS ON NRC REGULATIONS AND GUIDANCE APPLICABLE TO ISSUE NO. 16 Pursuant to the Licensing Board's Memorandum and Order (New Contention on Diesel Generators), dated December 23, 1983
(" Memorandum and Order"), slip op. at 8, Applicants file their reply to "OCRE Brief on Regulations and Guidance Applicable to Issue #10," dated January 16, 1984 ("OCRE Brief"), and "NRC Staff Response to Board Request for Briefs on the Regulations and Guidance Applicable to the Issue of the Reliability of Die-sel Generators," dated January 20, 1984 (" Staff Brief").1/
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" Applicants' Brief on NRC Regulations and Guidance Appli-cable to Issue No. 16"
(" Applicants' Brief") is dated January 27, 1984.
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Applicants disagree with both Ohio Citizens for Responsible En-ergy ("OCRE") and the NRC Staff (" Staff") concerning the scope of Issue No. 16 and the regulations and guidance applicable to b
T this issue.
1 I.
The Scope of Issue No. 16 Issue No. 16, as admitted to this proceeding, is as fol-lows:
Issue #16.
Applicant has not demonstrated that it can reliably generate emergency on-site power by relying on four Transamerica Delaval diesel generatcrs, two for each of its Perry units.
Memorandum and Order, slip op. at 1.
Issue No. 16 addresses the reliability of the standby diesel generators manufactured for Perry Nuclear Power Plant ("PNPP") by Transamerica Delaval, Inc. ("Delaval" or "TDI").
The basis for Issue No. 16 concerns the adequacy of the design and the adequacy of the quality as-surance program for the PNPP standby diesel generators..S_ee id.,
slip op. at.2-5.
The Staff in its brief correctly observes that "no specific issue concerning the reliability of the TDI diesel generators at the Perry plant has been identified."
Staff i
Brief at 1 (footnote omitted).2/
The Staff goes on to say that l
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See " Applicants' Answer to 'NRC Staff Supplemental Re-sponse (Based Upon New Information in Board Notification BN-83-160) to OCRE Motion For Admission To Resubmit Proposed Contention 2'",
dated December 16, 1983; " Affidavit of Edward J. Turk and Thomas G.
Swansiger in Support of Applicants' An-(Continued Next Page) ~ _., _
Q o
i the " Staff can only reference the entire group of regulations and guidance documents which pertain to diesel generators and documents generally used by Staff to review and evaluate the adequacy of diesel generators." Id. at 1-2.
However, the Staff concludes that "[bjeyond this, the reliability and safety of the diesel generators in connection with other systems, structures, and components in the plant must be addressed."
Id. at 2 (emphasis added).
Applicants disagree with the Staff that Issue No. 16 in-volves " systems, structures, and components in the plant" other than the standby diesel generators which were designed and man-4 ufactured by Delaval.
Nothing either in the language of Issue No. 16 or in OCRE's asserted basis for the issue 3/ suggests that any structure, system or component which is merely related (Continued) swer to 'NRC Staff Supplemental Response (Based Upon New Infor-mation in Board Notification BN-83-160) to OCRE Motion for Ad-mission To Resubmit Proposed Contention 2,'" dated December 13, 1983; Applicants' Reply to OCRE Response to Staff and Applicant Answer to OCRE's Motion To Resubmit its Contention #2, dated i
October 25, 1983; Applicants' Answer to Ohio Citizens for Re-sponsible Energy Motion To Resubmit its Contention #2, dated l
October 3, 1983.
3/
See "OCRE Response to Applicants' Answer to NRC Staff Sup-piemental Response re Proposed Diesel Generator Reliability Contention," dated December 22, 1983; "OCRE Response to Staff and Applicant Answer to OCRE's Motion To Resubmit its Conten-tion #2," dated October 14, 1983; " Ohio Citizens for Responsi-ble Energy Motion To Resubmit its Contention #2," dated September 16, 1983. 1
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or connected to the standby diesel generators, or which is not designed and manufactured by Delaval, is unreliable.
The standby diesel generators are part of the onsite electric power i
system.
They are connected or related to numerous other struc-tures, systems and components within that system, e.g.
- the i
batteries, the distribution system, the protection system - as well as to the offsite electric power system.
None of these i
other, connected or related structures, systems and components are within the Secpe of Issue No. 16; and the regulations and guidance applicable to such structures, systems and components are irrelevant to this issue.
i II.
Regulations Applicable to Issue No. 16 l
The Staff in its brief lists a number of the General De-sign Criteria ("GDC") of Appendix A to 10 C.F.R.,
Part 50 which l
it believes to be applicable to the reliability of the standby diesel generators.
These include GDC 1, 2,
3, 4,
5, 17, 18, 21, 44, 45, and 46.
Applicants agree that GDC 1, 2,
17, and 18 apply to Issue No. 16 insofar as they contain requirements for the standby diesel generators.
See Applicants' Brief at 2.4/
4/
Applicants do not agree with OCRE that the Appeal Board's
[
interpretation of GDC 17 with respect to standby diesel genera-l tors in Florida Power and Light (St. Lucie Nuclear Power Plant, l
Unit 2), ALAB-603, 12 N.R.C.
30 (1980), requires "the abandonement [ sic] of the single failure standard" of GDC 17.
OCRE Brief at 4 (emphasis added).
In St. _Lucie, the Appeal Board ruled that the reliability of onsite electric power is not sufficiently assured by the single failure criterion given the historical failure rate for standby diesel generators.
12 (Continued Next Page) l
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GDC 3 is generally relevant to the extent that it applies to fire hazards created by the standby diesel generators.
It is not applicable to the extent that it requires fire protection I
systems for the standby diesel operators, since such systems are separate from the diesel generators and Delaval did not de-1 sign or supply any such systems.
i The rest of the GDC cited by the Staff are clearly inap-plicable to Issue No. 16.
GDC 4 relates to the design of the j
diesel generator building.
GDC 5 concerns the sharing of structures, systems and components between units of the plant.
GDC 21 contains requirements for the protection system.
GDC 44, 45, and 46 relate to the cooling water system.
None of the.
above GDC concerns structures, systems or components which are l
part of the standby diesel generators and which were designed i
and manufactured by Delaval.
i III.
Regulatory Guides Applicable to Issue No. 16 OCRE in its brief acknowledges the rule of Gulf States Utilities Co. (River Bend Station, Units 1 and 2),
ALAB-444, 6 N.R.C.
760, 772-73 (1977), that regulatory guides do not repre-sent the only satisfactory means of meeting regulatory I
(Continued)
N.R.C.
at 48-52.
However, the Appeal Board did not rule that Applicants cannot rely at all on their ability to meet the in-l dependence and redundancy requirements of GDC 17 in de-monstrating the reliability of their standby diesel generators.,.. -
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requirements.
See OCRE Brief at 4.
The Commission in its Petition for Emergency and Remedial Action, C.L.I.-78-6, 7
N.R.C.
400, 406 (1978), has made clear that conformance with regulatory guides is not a prerequisite for meeting GDC.
OCRE nevertheless makes the surprising assertion that "in view of the unusual circumstances surrounding Delaval DGs, Applicants should have to show cause why compliance with these regulatory guides [concerning diesel generator reliability] (or even more stringent standards) is not mandatory."
OCRE Brief at 5 (em-phasis added).
OCRE cites no authority for this proposition.
Indeed, all of the authority which it cites is to the contrary.
There is no burden of proof on Applicants to show why they need not com-ply with potentially applicable regulatory guides.
Applicants' burden is to show that the PNPP standby diesel generators can reliably generate onsite electric power, whether by following the recommendations of regulatory guides or by other means.
i In fact, Applicants have committed to both regulatory guides identified by OCRE as applicable to the standby diesel generators - Regulatory Guide 1.9 5/ and Regulatory Guide 1.108.
5/
Applicants in the " Final Safety Analysis Report for Perry Nuclear Power Plant, Units 1 and 2" ("FSAR") Table 1.8-1 commit to Regulatory Guide 1.9,
" Selection of Diesel Generator Set Ca-pacity for Standby Power Supplies," Rev. O (March 10, 1971).
Rev. 2 of Regulatory Guide 1.9,
" Selection, Design, and Quali-fication of Diesel Generator Units Used as Standby (Onsite)
Electric Power Systems at Nuclear Power Plants" (December 1979), which is cited by OCRE, applies only to applications for (Continued Next Page) l l l
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' o See Applicants' Brief at 2-3.
Applicants have also committed to IEEE Standard 387-1977, which is endorsed by Regulatory Guide 1.9, Rev. 2.
See supra n.
5.
OCRE, however, would im-pose requirements on Applicants beyond the guidelines of IEEE Standard 387-1977:
"[S}ince the severe failures identified in i
Transamerica Delhval DGs place their reliability in grave doubt, the DGs to be used at PNPP should undergo the type testing of IEEE. Standard 387-1977, i.e.,
300 start and load tests, of at least 100 per DG, in place of the less stringent preoperational testing of Regulatory Guide 1.108."
OCRE Brief at 8-9.
OCRE apparently misunderstands the relationship between l
IEEE Standard 387-1977 and Regulatory Guide 1.108.
The 300 start-and-load tests recommended by IEEE ftandard 387-1977 are type qualification tests.
Regulatory Guide 1.108 supplements IEEE Standard 387-1977 by providing a program for
-preoperational and periodic inservice testing of the standby diesel generators.
IEEE Standard 387-1977, at 14, states that
"[d]iesel-generators of types not previously qualified as a (Continued) construction permits docketed after December 1979.
Id. at 1.9-3.
Applicants do commit, however, to IEEE Standard 387-1977, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Powers Supplies for Nuclear Power Generating Stations," which is endorsed by Regulatory Guide 1.9, Rev.
2.
See Applicants' Brief at 3.
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4 standby power source for nuclear power generating stations" shall be subject to the type qualification testing program (em-phasis added).
The PNPP standby diesel generators have been type ;1alified by the successful prototype testing of the Delaval standby diesel generators at Grand Gulf.
See NUREG-0887, Safety Evaluation Report Related to the Operation of Perry Nuclear Power Plant, Units 1 and 2 (May 1982),
S 8.3.1.
Applicants have committed to perform an additional 20 start-and-load tests on the PNPP standby diesel generators.
See id.; Letter from B.J. Youngblood to Murray R. Edelman (September 14, 1983) (Attachment 1 to this reply).
Applicants have thus conformed to the guidance of IEEE Standard 387-1977.
The Staff in its brief lists a number of regulatory guides in addition to those cited by Applicants and OCRE.
Only one of those regulatory guides, Regulatory Guide 1.29, " Seismic Design Classification," Rev. 3 (September 1978), applies to the stand-by diesel generators.
Applicants have committed to Regulatory Guide 1.29.
See FSAR Table 1.8-1.Q/
f/
Applicants note that there are two additional regulatory guides to which Applicants commit which relate generally to the ability of the diesel generators to withstand seismic events.
These are:
Regulatory Guide 1.48, " Design Limits and Loading Combinations for Seismic Category 1 Fluid System Components,"
Rev. O (May 1973); and Regulatory Guide 1.100, " Seismic Quali-fication of Electric Equipment for Nuclear Power Plants," Rev.
1 (August 1977).
See FSAR Table 1.8-1. -
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None of the additional regulatory guides cited by the Staff is relevant to Issue No. 16.
Regulatory Guide 1.26, at 1.26-1, explicitly states that the diesel generators are not covered by its provisions.
Both Regulatory Guide 1.6 and Regu-latory Guide 1.32 govern the design of the onsite electric power system, which was performed by Applicants' Architect-Engineer, Gilbert Associates, Inc. (" Gilbert").
Regulatory Guide 1.115 and Regulatory Guide 1.117 relate to the design of i
the diesel generator building, which also was designed by Gilbert and which is separate from the standby diesel genera-tors themselves.
Finally, Regulatory Guide 1.137 relates to I
the standby diesel generator fuel oil system, which is separate -
from the standby diesel generators.
Delaval did not design the fuel oil storage and transfer system for the PNPP standby die-sel generators, and Delaval supplied only the day tanks for l
that system.7/
Neither OCRE nor the Staff identifies any regulatory guides relevant to Issue No. 16 which relate to quality i
i 7/
In addition to the regulatory guides, the Staff in its j
brief, at 4-5, identifies several sections of NUREG-0800,
" Standard Review Plan for the Review of Safety Analysis Reports 4
for Nuclear Power Plants" ("SRP"), as applicable to Issue No.
16.
Three of these sections are in fact inapplicable.
SRP S9 3.6.1 and 3.6.2 (mistakenly cited as 8.3.1) govern such items as coolant water pipes and fuel lines which are connected with i
but separate from the standby diesel generators and which were j
not designed or manufactured by Delaval.
SRP 5 9.5.4 concerns i
the standby diesel generator fuel oil storage and transfer sys-l tem discussed supra.
I
,w assurance.
However, Applicants wish to clarify statements made in Applicants' Brief, at 3-4, concerning regulatory guides relating to quality assurance which are generally applicable to the PNPP standby diesel generators.
At the construction stage, the only regulatory guide relating to quality assurance to which Applicants committed is Regulatory Guide 1.58, "Qualifi-cation of Nuclear Power Plant Inspection, Examination, and i
Testing Personnel," Rev. O (August 1973).
See Preliminary Safety Analysis Report for Perry Nuclear Power Plant, Units 1 and 2 ("PSAR"), 5 17.1.10.1.
In addition, Regulatory Guide 1.38, " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nu-clear Power Plants," Rev. 0 (March 1973) was included as a re-quirement in the specification for the standby diesel genera-tors.
Other applicable regulatory guidec considered in the development of Applicants' quality assurance program for cen-struction of PNPP but not committed to include:
Regulatory i
Guide 1.28, " Quality Assurance Program Requirements (Design and i
Construction)," Rev. O (June 1972); and Regulatory Guide 1.30,
" Quality Assurance Requirements for the Installation, Inspec-tion, and Testing of Instrumentation and Electric Equipment,"
Rev. 0 (August 1972).
Applicants' quality assurance commit-ments during the design and construction of the PNPP standby diesel generators are contained in Chapter 17 of the PSAR and l
in the Corporate Nuclear Quality Assurance Program for the l
construction stage.
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For purposes of operation of PNPP, Applicants have commit-ted to the following additional regulatory guides relating to quality assurance which are generally applicable to the standby diesel generators:
Regulatory Guide 1.2G, Rev. 2 (February 1979); Regulatory Guide 1.33, " Quality Assurance Program Re-quirements (Operations)," Rev. 2 (March 1978); Regulatory Guide 1.38, Rev. 2 (May 1977); Regulatory Guide 1.58, Rev. 1 (September 1980); Regulatory Guide 1.116, " Quality Assurance Requirements for Installation, Inspection, and Testing of Me-chanical Equipment and Systems," Rev. 0 (May 1977); Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants,"
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Rev. 1 (July 1977); and Regulatory Guide 1.144, " Auditing of Quality Assurance Programs for Nuclear Power Plants" (January 1979) (for comment).
See FSAR Table 1.8-1.
IV.
Industry Standards Applicable to Issue No. 16 In addition to ragulations and regulatory guides, the l
Staff in its brief, at 5-6, lists a number of industry stan-dards referenced in regulatory guides which it asserts apply to standby diesel generators.
Of these industry standards, the following are not relevant to Issue No. 16.
ANSI N175, " Fuel Oil Systems for Standby Diesel Generators," is not applicable for the reasons discussed supra with respect to the fuel oil storage and transfer system.
Neither do the ASTM Standards for i P
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c Determining Fuel Oil Quality relate to the design or manufac-ture of the standby diesel generators.
Finally, IEEE 308-1974 concerns the design of the safety related electric power sys-l tems for PNPP, which was performed by Gilbert.
OCRE in its brief, at 6-7, also cites a number of industry standards which are referenced in IEEE 387-1977.
Of these, the following standards are irrelevant to Issue No. 16.
ANSI j
C50.5-1955, ANSI C50.10-1977, ANSI C50.12-1965, IEEE Standard 115-1965 and NEMA MG-1-1972 all relate to the generators, which are not diesel engine components and were manufactured by Gen-eral Electric.
API Standard 650 applies to the fuel oil stor-age and transfer system, discussed supra.
IEEE Standard i
308-1974 is inapplicable for the reasons stated supra.
IEEE l
Standard 323-1974 is the general standard for qualifying all j
safety related electrical equipment, and is relevant only insofar as it applies to the standby diesel generators.
IEEE Standard 387-1977 provides the specific standards for quali-fying the standby diesel generators.
V.
Staff and Contractor Reports OCRE identifies several staff and contracts reports containing generic information on diesel generators.
See OCRE Brief at 9.
OCRE acknowledges that it has not analyzed the documents to see if they contain any information relevant to Issue No. 15.
However, OCRE " propose [s] that the parties be "
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permitted to rely on such publications, if they are relevant to Issue No. 16, on Delaval DG reLLE6iligt and if they are sup-ported by other evidence."
Id.
l Applicants do not object to Staff and contractor reports as potential sources of relevant information on Issue No. 16.
A determination of relevance would, of course, turn on an anal-ysis of each particular document.
However, Applicants cannot 4
i agree if OCRE is suggesting that special evidentiary rules be applied to permit the submission into evidence of Staff and contractor reports otherwise inadmissible because unattested to by a witness or by affidavit.
l Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Sy:
&ICLOLLA 0.
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Jay E.
- Silberg, P.C. V
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Michael A.
Swiger l
Counsel for Applicants 1900 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 l
i Dated:
February 3, 1984 -
UNITED STATES NUCLE AR REGUL ATORY COM*.ilSSION i
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Docket Nos. :
50-440 and 50-441 Mr. Murray R. Edelman Vice Presidert - Nuclear Group The Cleveland Electric !11cT.inating Company P. O. Box 5000 Cleveiand, Ohio a4101
Dear ' '. r. Edelman:
Su je:t:
Acceptability cf the Diesel Generator Tests for Cerry NJClear Power Fian (drits 1 and 2)
Your letter da:ed Jur.e 15, 1933 clarified your com-i: ment to perform a total of 20 start-and-load tests in adcition to the plant preoperationel test cre-inis acditio,nal testina would result in a total of 39 tests for the cran.
.. -..- tests on one generator and 4,, tests on the other ciese,i generators ici /1:e: -:
standby diesel genera:cr}
Ycu advised tha: the 20 additional start-and-load tests v:ill be concucted in accordance i:5 Reguistory Suice 1.9 and IEEE Standarc 387-1977, Section 6.3.2, witn cne exce: tion.
Since a single steo the d'esel gererator nameolate cor.tinuous rating is not avail-icac of 50 c'
aole in the plant, you :lan tc load the genera:Or witn the available bus load cnce it has attained the necessary speed and voltage.
The bus will then be synch :nized
- h offsite power and 10ade: as 0;ickly as possible :: 50E of
'at'
~ne : e::eri:': i rellatili > testin;. re re # r~ed in accordance
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y The staff has -eviewec your clarification for the diesei generator tes: and
'inds the :: ce accepta:le.
We plan to incorp; rate nis 'ind'n; in :ne next SER succle ent, uncer Se:: ion E.3.1, schedaiec to be issue: in Novem:er '.952.
In adcition, the NRC Power Systems Branch staff reviewer (S. C. Rhow) intenas to conduct an onsite audit of the plant electrical power systems during the week of September 26, 1983.
Specific dates, times, and an agenda for the areas to be audited will be announced separately.
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- f y u have ar.y questions, clease direct :ner to tne Perr;. or; ject :anager.
John J. Stefar.o.
Sincere.ly, A
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W S. J/ Youngblood, Chief Licensinc Branch No. 1
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6 f-February 3, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Reply to NRC Staff and Ohio Citizens for Responsible Energy Briefs on NRC Regulations and Guidance Applicable to Issue No. 16" were served by deposit in the United States Mail, First Class, postage prepaid, this 3rd day of February, 1984, to all those on the attached Service List.
+7),amd Q. -5D :y Michael A.
Swiger l
DATED:
February 3, 1984 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
TEE CLEVELAND ELECTRIC
)
Docket Nes. 50-440 ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear Power ' Plant,
)
Units 1 and 2)
)
SERVICE LIST _
Atcmic Safety and Licensing Peter B. Bloch, Chairman Appeal Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section Dr. Jerry R. Kline Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Colleen P. Woodhead, Esquire Mr.'Glenn O. Bright Office of the Executive Legal Atomic Safety.and Licensing Board Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Christine N. Kohl, Chairman Ms. Sue Hiatt Atomic Safety and Licensing OCRE Interim Representative Appeal Board U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Menter, Ohio 44060 Terry Lodge, Esquire Dr. W.
Reed Johnson 618 N. Michigan Street, Suite 105 Atomic Safety and Licensing Toledo, Ohio 43624 Appeal Board U.S. Nuclear Regulatory Commission Donald T. Ezzone, Esquire Washington, D.C.
20555 Assistant Prosecuting Attorney Lake County Administration Center Gary J. Edles, Esquire 105 center Street Atomic Safety and Licensing Painesville, Ohio 44077 Appeal Board U.S. Nuclear Regulatory Commission John G. Cardinal, Esquire Washington, D.C.
20555 Prosecuting Attorney Ashtabula County Courthouse Atomic Safety and Licensing Jefferson, Ohio 44047 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- __ ________