ML20083B479

Submittal of Rept on Emergency Diesel Generators,Per ASLB 831212 Request.Certificate of Svc Encl

ML20083B479
Person / Time
Site:	Limerick
Issue date:	12/19/1983
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20083B476	List: ML20083B474 ML20083B479
References
NUDOCS 8312210173
Download: ML20083B479 (29)

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!t 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board '

In the Matter of

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S SUBMITTAL OF REPORT ON EMERGENCY DIESEL GENERATORS Pursuant to the Licensing Board's request of October 17, 1983 at the Prehearing Conference (Transcript at 4604, 4608-09), I am transmitting Applicant's Response to Licensing Board's Request for Information Relating to the Limerick Emergency Diesel Generators dated December 12, 1983. Copies were distributed to the Board as well as parties in attendance at the evidentiary hearing on Thursday, December 15, 1983 (Transcript at 5700).

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for Philadelphia Electric Company December 19, 1983 8312210173 831219

{DRADOCK 05000352 PDR

}

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) Docket Nos. 50-352 Philadelphia Electric Company ) 50-353

)

(Limerick Generating Station, )

Units 1 and 2) )

RESPONSE TO LICENSING BOARD'S REQUEST FOR INFORMATION PERTAINING TO THE LIMERICK EMERGENCY DIESEL GENERATORS

Abstract This report was developed by Philadelphia Electric Company (PECo) in response to a request from the Atomic Safety and Licensing Board for information pertaining to the Limerick Emergency Diesel Generators.

This request was made at the Prehearing Conference held in Phoenixville, PA on October 17 and 18, 1983.

There are eight Fairbanks/ Morse Model 38TD8 1/8 diesel generators at Limerick, four associated with each unit. This model diesel generator is of a proven design and has provided excellent reliability in the nuclear power industry for over fifteen years, including approximately ten years of service at PECo's Peach Bottom Atomic Power Station. As a result of Peach Bottom experience, PECo has developed a thoroucjh operation and maintenance program and has made numerous improvements in the design of the diesel generators which will be applied to Limerick.

The Limerick diesels are subject to a comprehensive testing program, both before fuel load and throughout the life of the plant.

-This testing program has been based on current regulatory requirements and Peach Bottom experience. It censists of three phases: (1) factory shop tests prior to shipment, (2) preoperational tests, and (3) periodic surveillance tests after fuel load. Along with the proven effectiveness of PECo's operating practices, these tests will ensure that the Limerick diesels will provide highly reliable service throughout the lifetime of the plant.

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Table of Contents Section Page I. General Description 1 II. Philadelphia Electric Co. Diesel Generator Experience 2 III. Limerick Diesel Generator Test Programs 7 IV. Conclusion 14 V. References 20 ii

I. General Description The emergency diesel generator system at Limerick consists of eight Fairbanks-Morse 12-cylinder Model 38TD8-1/8 opposed piston engines, four dedicated to each unit. Each engiae is equipped with a Beloit Power Systems Model TGZ-DJ single-bearing alternator. The same basic model diesel generator is being used at the following nuclear power plants:

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Robinson 2 Prairie Island 1 & 2 Vermont Yankee Three Mile Island 1 & 2 Calvert Clifts 1 & 2 Crystal River 3 E.I. Hatch 1 & 2 Duane Arnold North Anna 1 & 2 Millstone 1 & 2 Farley 1 & 2 Arkansas Nuclear One, 2 Peach Bottom 2 & 3 Fermi 2 Each diesel generator is rated at 2850 kW for continuous operation and 3135kW for two hours of operation in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

The standby power supply for each unit at Limerick consists of four independent Class 1E busses, each powered by one of the four inde-pendent diesel generators. Operability of three out of four diesel generators is required to satisfy the Class IE load demands caused by a Design Basis Loss of Coolant Accident (DBA LOCA) with concurrent Loss of Offsite Power (LOOP). For all other situations, operability of a maximum of two diesels is required to ensure the safe shutdown of the plant.

The Limerick diesel generators have been subjected to a comprehen-sive quality assurance and quality control program throughout their design, manufacture, installation, and testing. Appropriate design, material certification, examination, and testing requirements have been applied. These requirements extend beyond the provisions of the manufacturer's Quality Assurance Plan as applied to other diesel m

generator orders. Supplemental quality assurance requirements were applied to selected, important diesel generator and auxiliary system components. These supplementary requirements are discussed in detail in the Limerick FSAR, Section 3.2.1.

II. Philadelphia Electric Co. Diesel Generator Experience Fairbanks-Morse diesel generators were selected for use at Limerick because their reliability has been proven in over 40 years of industrial and marine service. The 38TD81/8 diesel has been in service at nuclear power plants for over fif teen years, and four units have been in service at PECo's Peach Botton Atomic Power Station for approximately ten years.

PECo's operating experience with these diesels at Peach Bottom has been excellent. In over 2000 tests, only about 15 failures to start and/or sustain load have been experienced. This performance record indicates greater than 99% reliability and is exceptional in the industry. This represents approximately one-half the number of test failures that would have been experienced had the reliability of the Peach Bottom diesels been equal to the industry average. This relia-bility may be attributed to PECo operational and maintenance practices

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which reflect consideration of all manufacturers' recommendations and applicable industry-wide experience. In addition, each diesel generator at Peach Bottom is disassembled, inspected, and overhauled as necessary on an annual basis. The inspection focuses upon those areas of the diesel known to be subject to operational degradation, such as valves, bearings, crankshaft 3, anu other moving parts. A representative of the manufacturer is brought on-site to provide technical guidance during this work. A similar operational and maintenance program will be I

employed at Limerick.

Each Peach Bottom diesel test failure is analyzed in detail, and appropriate corrective actions are taken to mitigate the potential for recurrence of similar failures at Peach Bottom or Limerick. Examples of these corrective actions are discussed below:

1. At least two of the Peach Bottom test failures occurred due to the misalignment of diesel skid-mounted auxiliary system valves. Investigations determined that more detailed Piping and Instrumentation Diagrams were needed to enable the i

operators to accurately and consistently perfonn necessary i

l operations. As a result of this determination, each diesel auxiliary system was inspected and appropriate controlled drawings were developed. Examples of the drawings provided for Limerick are shown in LGS FSAR Figures 9.5-8 through 9.5-12, inclusive.

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2. Degraded diesel performance was experienced at Peach Bottom due to governor malfunctions. Governors of an improved design have been installed in the Peach Bottom and Limerick diesels. '

3. Problems were experienced at Peach Bottom with the air start I

control valves. Investigations indicated that these malfunc- ,

i tions were due to particulate contamination of the starting air. Specially designed, particulate-immune valves have been installed at Peach Bottom and Limerick.

As a result of experiences throughout the rest of the nuclear power industry, a number of improvements have also been made in the design of the Limerick diesel generators and auxiliary systems.

Examples of such improvements are discussed below:

1. The air start system for each engine is completely inde-pendent. Because there are no interconnections, a failure or misalignment in one air start system cannot result in failure of mere than one diesel generator.

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2. The air start system on each diesel generator is comprised of two redundant air start subsystems. Each subsystem supplies starting air to six of the twelve cylinders. Both subsystems normally operate during the startup transient; however, tests have proven that each subsystem alone is capable of starting the engine more than five times in under ten seconds without compressor assistance.

3. In order to minimize the potential for corrosion, none of the pipes, valves, filters, or receivers in the air start systems is made of exposed carbon steel.

4. The combustion air intake system has a mechanical positive displacement blower in series with the turbocharger dis-charge. This provides more complete scavenging at light load operation, higher combustion ratios, cooler c.xhaust temp-eratures, and increased thermal efficiency and thereby greater reliability.

PECo keeps apprised of operating experiences throughout the nuclear power industry by using appropriate sources of information.

NRC Inspection and Enforcement Bulletins, Circulars, and Information Notices are reviewed for applicability to Peach Bottom and Limerick, and the results of these reviews including any appropriate corrective actions are permanently documented. In addition, re3evant INPO Signifi-cant Event Peports and Significant Operating Experience Reports, NRC Licensee Event Reports, NUREG's, and EPRI reports are reviewed by cognizant engineering and operations personnel. If these reviews

indicate a . potential problem at either Peach Bottom or Limerick, appropriate corrective actions are taken. These may include procedural revisions and/or hardware modifications. Recent examples of PECo consideration of reported diesel generator problems are presented below:

1. The E.I. Hatch plant experienced repeated failures of their upper crankshaft bearings. Hatch prelubricated their engines for only one minute prior to each test start, whereas the manufacturer recommended a three minute prelube. PECo confirmed that the design and proceditres for the operation of the Peach Bottom and Limerick emergency diesels utilize the recommended three minute prelube cycle.

2. The Dresden plant experienced fsilures of the diesel gen-erator cooling water check valves. PECo maintenance pro-cedures have been revised to require that all valves in similar service at Peach Bottom and Limerick are disassembled and rebuilt during the annual overhaul on each diesel generator.

3. A control logic problem at Millstone and North Anna prevented automatic restart of the diesel generators for a period of

! time following engine shutdown. If an emergency start signal i was present, starting air would continue to be fed into the cylinders, and air start system depletion would result. The control logic design for both the Peach Bottom and Limerick diesels has been reviewed by PECo, and it has been determined that analogous problems could develop. Modifications are currently being implemented at both plants to rectify this concern.

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. i III. Limerick Diesel Generator Test Programs The Limerick diesel generators are subjected to a comprehensive testing program both before fuel load and thrcughout the life of the plant. This testing program has been based upon the following documents as well as our PBAPS operating experience:

l. NRC Regulatory Guide 1.108, Revision 1 (8/77): " Periodic Testing of Diesel Generator Units used as Onsite Electrical i

Power Systems at Nuclear Plants."

2. IEEE Trial Use Standard No. 387-1972: " Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations."

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j 3. IEEE Standard No. 387-1977: " Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear l

Power Generating Stations."

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4. Standard Technical Specifications for General Electric Boiling Water Reactors (NUREG 0123).

5. Colt /Fairbanks-Morse Operation and Maintenance Manual for i Limerick Diesel Generators. (Limerick Vendor Print No.

, 8031-M-71-387-1-3S).

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s The Limerick diesel generator testing program consists of three '

phases: (A) factory shop tests prior to shipment, (B) preoperational testing, and (C) periodic surveillance testing after fuel load. Each phase is discussed in detail below:

A. Factory Shop Testing I

i As required by the procurement specification, each of the eight Limerick diesel generator units was extensively tested at the factory i

in Beloit, Wisconsin after assembly of each unit was complete. The i

following is a brief description of each of these tests:

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l. Functional tests - Prior to any tests which required actual running of the engine, each of the units was subject to the following tests:

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a. Piping Integrity Tests - The piping on the skid-mountea jacket water, air coolant, lube oil, starting air, and fuel oil systems was required to pass a hydrostatic test at 1.25 times the design pressure.

b. Control Circuit Tests - The electrical control circuits l

were tested to insure proper wiring and equipment function,

c. Generator Electrical Tests - A series of reactance tests and resistance measurements were conducted on the generator internals, and verified to be within acceptable ranges.

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d. Operating Checks of Lube Oil Pumps - Proper operation of the keepwarm circulating pump and the prelube pump was i verified by visual observation of oil flow in the crankcase interior.

e. Air Compressor Test - Correct air compressor sizing was verified by demonstrating that one compressor could charge both air receivers from 0 to 250 psig in less than 30 minutes.

f. Fuel Oil Injectors -

Each injector was functionally tested and calibrated to deliver a metered amount of j fuel to the combustion chamber.  !

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, 2. Operational Tests - After completion of the functional tests, each of the units war exercised according to the manufacturer's standard run-in schedule in order to assure proper engine wearing-in. The engine and generator were also dynamically balanced. Following this preliminary exercising, a series of operational tests were conducted on each unit as discussed '

below:

a. Overspeed Test - Proper operation of the governor overspeed trip was demonstrated by manually increasing the engine speed above the rated speed of 900 rpm until i

a trip occurred.

b. Fast Start Capability Tests - Each engine was demonstrated to be capable of accelerating to its rated speed and full voltage and ready to accept load to its rated capacity in not more than 10 seconds.

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c. Air Start System Capacity Tests - The capability of the air start system for each diesel was verified to provide at least five starts in less than 10 seconds without compressor assistance for each of the following configurations:

1. Starting air supplied to cylinders 3-6 only from one air tank.

2. Starting air supplied to cylinders 7-12 from the other air tank.

3. Starting air supplied to all 12 cylinders from both air tanks.

The results of these tests demonstrated that each Limerick air start system has sufficient capacity to provide well over the minimum number of redundant starts required by the regulations,

d. Load Acceptance Test - The ability of each diesel generator to accept incremental load changes without an excessive drop in voltage was demonstrated. Each diesel generator was required to accept loads from 0 to 100% of rated value in both 25% and 50% increments, with no greater than a 25% drop in output voltage permitted.

Recovery following the initial voltage drop was verified to be within 10% of normal output voltage within one second, with a frequency deviation of no greater than 5%.

e. Load Rejection Test - The ability of each diesel generator to operate properly during load shedding was also verified. The tests consisted of a complete loss of rated load, as well as incremental losses of 25% and 50%

load. It was verified that the voltage and frequency limits described above were not exceeded and that the resultant engine speed increase was less than 100 rpm.

f. Performance Testing - Each diesel generator was subject to a series of performance tests in which the standard engine operating parameters (e . g . , fuel consumption, intake temperatures and pressures, exhaust temperatures and pressures, and cooling media temperatures and pressures) were determined for various load values from 0 to 110% of rated load.

The contract tests for the first diesel generator unit were witnessed by representatives of Colt /Fairbanks Morse, PECo, and Bechtel Power Corporation. Tests on the remaining units were witnessed by Colt and Bechtel, representing PECo. Detailed tabulations of the results of each of the above tests were provided by the manufacturer, in compliance with the requirements of the procurement specification.

B. Preoperational Testing After installation at-the site, and prior to the Units' fuel load, its diesel generators will be subject to a comprehensive preoperational testing program. A brief description of the principal aspects of this test program is presented below:

1. Testing Prerequisites - Prior to commencement of the formal diesel generator testing program, the following prerequisites will be completed:

a. Visual Examination - All principal components will receive a visual examination for any cigns of gross damage,

b. Component Technical Tests -

Each functioning component of the diesel generator system which cannot be tested by direct simulation of operating conditions (e.g. relief valves), will be tested Fi prior to installation.

c. Support Systems Tests - Required diesel generator support systems such as the emergency service water system, the diesel generator enclosure HVAC system, the fuel oil storage and transfer system, the 4kV buses, etc. will be tested to confirm proper operation.

d. Instrument Calibration - All instruments will be calibrated and the required records verified to be on file.

e. Flushing - Each segment of the piping systems will be flushed to ensure proper levels of cleanliness, and the results verified to be on file,

f. Piping Integrity Test - The piping on the cooling water, lubricating oil, starting air, and fuel oil systems will be subjected to a hydrostatic test at 1.25 times design pressure.

2. Auxiliary System Functional Tests - Prior to any test which requires actual running of the engine, the following tests will be performed:

a. Keepwarm System Test -

Proper operation of the lubricating oil and jacket water keepwarm systems will be demonstrated.

b. Prelube System - The engine prelubrication system 1

will be verified to operatt for a three minute period from (1) remote manual actuation from the i

control room (as will be done prior to each test start), and (2) local actuation from the diesel

generator cell. Verification will be accomplished by visual observation of flow in the crankcase interior.

c. Crankcase Level Control - The float valve in the interior of the crankcase will be verified to i

maintain the correct lubricating oil level in the i

t crankcase sump.

d. Fuel Oil Pumps - The transfer pumps from the fuel oil storage tanks, and the D.C. auxiliary fuel oil supply pump to the engine, will be demonstrated to operate properly in both automatic and manual

, modes.

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e. Air Compressor Tests - Each air compressor will be demonstrated to be capable of charging each of the air receivers in less than thirty minutes. Follow-ing this, the ability of each air compressor to automatically maintain a charge of between 225 psig and 250 psig in its associated air receiver will be confirmed,

f. Electrical Circuit Tests - Each of the electrical power supply and control circuits will be tested to ensure proper wiring ara component function. In addition, each of the engine relays, functional interlocks, alarms, and protective shutdown features will be confirmed to operate properly.

g. Generator Space Heater - Proper operation of the space heater provi ded for generator shutdown temperature control is verified for both automatic and manual modes.

h. Generator Breaker Tests - Each of the diesel output breakers is verified to be capable of closure in either automatic or manual modes. Each breaker is verified to be capable of closure to either an energized or deenergized emergency bus, and is also verified to trip in the presence of a LOCA signal received during a test run.

3. Operational Tests - After satisfactory completion of the functional tests, a series of operational tests will be conducted on each unit as discussed below:

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a. Fast Start Capability - Each diesel generator will be demonstrated to be capable of accelerating to its rated speed and voltage, and ready to accept load in not more than 10 seconds. This acceptance criteria is applied to each start of the diesel generators throughout the test program.

b. Overspeed Test - The proper operation of the governor overspeed trip will be demonstrated in the same manner as in the contract tests.

c. Air Start System Capacity - The capability of the air start system to provide at least five starts in less than ten seconds will be verified for each of the configurations discussed in the contract tests description,

d. Manual Starts - The ability of each diesel generator to accelerate to rated speed and voltage upon receipt of either a remote-manual start signal from the control room or a start signal from the local control board is confirmed. Proper sequencing of the prelube pump is also verified during these tests.

e. LOCA Automatic Starts - The capability of each diesel generator to automatically start upon receipt of a LOCA signal (either low reactor water level or high drywell pressure coincident with low reactor pressure) and accelerate to rated speed and voltage will be confirmed.

f. Loss of 4kV Power Test - Each diesel generator is verified to automatically start and accelerate to rated speed and voltage upon receipt of a LOOP signal (total loss of 4kV power to Class lE grid).

g. Design Accident Load Acceptance - Each diesel generator will be verified to automatically start and accelerate to rated speed and voltage upon receipt of a LOCA signal with coincident LOOP. The plant emergency loads (e.g. RHR pumps, core spray pumps, etc.) will then be sequentially applied, and each diesel generator will be verified to experience no more than a 25% drop in output voltage. Subsequent recovery will be verified to be within 10% of normal output voltage within one second, with a frequency deviation of no greater than 5%.

h. Restoration of Offsite Power Test - With the diesel generator operating with its emergency loads under a simulated DBA LOCA with LOOP, a restoration of offsite power test will be conducted whereby the diesel generator will be verified to: (1) synchronize with the offsite power source, (2) transfer its loads to the offsite power source, and (3) return to standby status,

i. Load Rejection Test - The ability of each diesel generator to operate properly during load shedding will also be verified. The tests consist of a complete loss of rated load, as well as a loss of the single largest emergency load (a PHR Pump).

These tests are performed to verify that the voltage and frequency limits are not exceeded and that the accompaning engine speed increase does not cause an overspeed trip.

j. Governor Override Test - The capability of the governor to return the diesel generator to automatic (isochronous) mode if an emergency start signal is received while the diesel is in test (droop) mode will be verified.

k. Performance Tests - Each diesel generator will be operated continuously for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, of which 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> will be at a load equivalent to the continuous rating of the diesel generator (2850 kW), and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be at a load equivalent to the peak rating of the diesel generator (3135 kW) .

At the start of this test, and at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intervals thereafter, it will be verified that the output voltage and frequency limits are maintained, and that the lube oil consumption rate and fuel oil consumption rate do not exceed the baseline data obtained during the contract tests.

1. Reliability Tests - The reliability of each diesel generator will be demonstrated by starting each a minimum of 23 consecutive times with no failures.

Each of the above tests will be conducted on a single diesel generator unit at any one time. In addition, a Total Loss of Offsite

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Power Test will be conducted in which the four diesel generator units will be started simultaneously. This will identify any potential common failure modes undetected in the individual tests. All of the above' tests will be conducted by the PECo/Bechtel startup group.

C. Periodic Testing After fuel load, and throughout the life of the plant, each diesel generator will be subject to a periodic surveillance test program in order to ensure their continued availability. This pr~92am is currently under development, but will in general conform to Section 4.8.1.1.2 of the GE Standard . Technical Specifications (NUREG-0123). Principal aspects of this test program are as follows:

1. Normal Operation - During plant operation, each diesel generator will be subject to the following surveillance requirements:

a. Test Starts - In order to maintain an adequate oil film on the bearings in the event of an emergency start, PECo will test each diesel on a weekly basis. In no case will the time interval between tests exceed the limits specified in Table 4.8.1.1.2-1 of !!UREG-0123, which are predicated upon the prior failure history of the diesels,

b. Chemical Analyses - Tests will be conducted on the engine jacket water, lubricating oil, and fuel oil at periodic intervals to verify that no unacceptable degradation of either the process media or the engine has occurred.

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2. Refueling Outages - At eighteen month intervals, during shutdown, each diesel generator will be subject to each of the operational tests discussed in Section III.B.3, above, except for the 23 start reliability tests discussed in Paragraph III.B.3.k. In addition, functional tests will be cca - ;ted on the diesel generator trip bypass logic and the fuel oil storage and transfer system interconnections.

These tests will be conducted by PECo Electric Production op-erating personnel, and will be in accordance with specific, written surveillance test procedures. These procedures will be developed and implemented prior to plant fuel load.

IV. Conclusion Each of the eight diesel generators to be used at Limerick satis-factorily completed the contract test requirements discussed in Section III prior to shipment from the factory. The four diesel generators assigned to Unit 1 have been installed at the plant; the Unit 2 diesels are currently in storage. As of the date of this report, the diesel generator preoperational test procedures for Unit 1 are in their final stages of development, prerequisite testing is in progress, and pre-operational testing is scheduled to begin in January, 1984, with completion in May, 1984.

Based upon the extensive testing program imposed on the Limerick diesel generators, their proven design, and the proven effectiveness of PECo's diesel generator operation and maintenance practices, PECo is confident that the Limerick emergency diesel generators will provide highly reliable service throughout the lifetime of the plant.

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V. REFERENCES e

The following references were used in the development of this

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report:

1. Colt /Fairbanks Morse Contract Test Logs and Witness Test Reports for Limerick Diesel Generators. (Limerick Vendor Print Nos. 8031-M-71-225 through 228, inclusive).

2. Colt /Fairbanks-Morse Operation and Maintenance Manual for Limerick Diesel Generators. (Limerick Vendor Print No.

8031-M-71-387-1-3S).

3. EPRI Report No. NP-2433: " Diesel Generator Reliability at Nuclear Power Plants: Data and Preliminary Analysis."

Interim Report, June 1982.

4. IEEE Trial Use Standard No. 387-1972: "Cr'teria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations."

5. IEEE Standard No. 387-1977: " Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations."

6. Limerick Generating Station Preoperational Test Procedure No.

IP-24.1: " Standby Diesel Generators System; Startup System

! 24A." Revision 0 (Draft) .

7. NRC Regulatory Guide 1.108, Revision 1 (8/77): " Periodic Testing of Diesel Generator Units used as Onsite Electrical Power Systems at Nuclear Plants."

8. Philadelphia Electric Company, Limerick Generating Station:

Final Safety Analysis Report, through Revision 26 (11/83).

9. Standard Technical Specifications for General Electric Boiling Water Reactors (NUREG 0123).

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i LAW OFFICES 00(.KETED

'JStiRC GONNER 6e WETTERHAHN. P.G.

1747 PENNSYLVANI A AVENU E. N. W.

Mann E wETTE HANN Rong M. MADER

"$"d*woonE."a a.*

A3 OFFICE OF SECRt.lAN' won E=T u. ec=L December 19, 1983 00CKETihG4,#4fMboo

• % r* E ",',",'. . . ,, c . BRANG CABLE ADDRESS: ATo M LAW Mr. Frank R. Romano 61 Forest Avenue Ambler, Pennsylvania 19002 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353

Dear Mr. Romano:

The Applicant's responses to AWPP's second and third requests for information, documents, etc. are being transmitted to you under separate cover today. These responses have been designated as " Discovery 16" and

" Discovery 17," respectively. It should be noted that the name of the welder identified in response to AWPP's third request under Item 4 falls under the Protective Agreement executed by AWPP and Philadelphia Electric Company and should be treated as provided for therein. It should also be noted that there are no documents requested under either of these requests which have not been previously provided.

Therefore, there are no documents specifically being made available at the Company's document room pursuant to these requests.

With regard to our telephone conversations today, I was not able to arrange for a meeting between you and the appropriate Philadelphia Electric Company technical personnel for tomorrow on such short notice. I understand that you are not available for a meeting for the remainder of this week, but may be available next Tuesday. I am attempting to confirm this date with Philadelphia Electric Company.

4 i Mr. Frank R. Romano

D ctmber 19, 1983

• Page 2 A copy of the executed Protective Agreement is also enclosed.

Sincerely, p n Mark J. Wetterhahn Counsel for Philadelphia Electric Company MJW:sdd cc: Service List

00LKETED U3NRC

'83 EC 20 N1 :04 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FflCE OF SLCELIM 00CKEIING & SERVE BRANCH In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Submittal of Report on Emergency Diesel Generators," letter from Mark J. Wetterhahn to Mimie Meltzer, and letter from Mark J. Wetterhahn to Frank R. Romano, all dated December 19, 1983 in the captioned matter, have been served upon the following by deposit in the United States mail this 19th day of December, 1983:

Judge Lawrence Brenner (2) Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section Judge Richard F. Cole Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission IL S Nuclear Regulatory Washington, D.C. 20555 Commission Weshington, D.C. 20555 Ann P. Hodgdon, Esq.

Counsel for NRC Staff Judge Peter A. Morris Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

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Atomic Safety and Licensing Steven P. Hershey, Esq.

Board Panel Community Legal U.S.. Nuclear Regulatory Services, Inc.

Commission Law Center West North Washington, D.C. 20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN: Edward G. Bauer, Jr. Angus Love, Esq. 101 East Vice President & Main Street Norristown, PA General Counsel 19401 -

2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.

Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 306 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I. Lewis Basement, Transportation 6504 Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq. Martha W. Bush, Esq.

Limerick Ecology Action Kathryn S. Lewis, Esq.

P.O. Box 761 City of Philadelphia 762 Queen Street Municipal Services Bldg.

Pottstown, PA 19464 15th and JFK Blvd.

Philadelphia, PA 19107 Charles W. Elliott, Esq.

Brose and Postwistilo Spence W. Perry, Esq.

1101 Building lith & Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840 Zori G. Ferkin, Esq. Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radia*4on 1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmentaa Resources 5th Floor, Fulton Bank tidg.

Third and Locust Streets Harrisburg, PA 17120

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t Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 l

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