ML20086L291

Requests NRC Undertake Complete Insp of Each of 24 Cylinder Heads Installed in Facility Diesels for Compliance W/Applicable Stds.Ie Insp Rept 50-322/83-25 Re Transamerica Delaval,Inc Diesel Generators Encl

ML20086L291
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/03/1984
From:	Dynner A KIRKPATRICK & LOCKHART
To:	Harold Denton Office of Nuclear Reactor Regulation
References
ISSUANCES-OL, NUDOCS 8402080167
Download: ML20086L291 (10)

Text

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KIRKPATRICK, LOCKHART, HrLL, Cunrsroenna & PurLLrrs A Paarmamourr homma A PeormessonAs. ConromArsom 1900 M Srnnut, N. W.

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202/452-7044 (BY MESSENGER)

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Room P-404A Bethesda, Maryland 20814 Re: Long Island Lighting Company; Shoreham Nuclear Power Station, Unit 1; Docket No. 50-322-OL

Dear Mr. Denton:

On Thursday, January 26, you chaired a meeting on diesel generators manufactured by Transamerica Delaval, Inc. ("TDI") at which you expressed your concern with the many problems experi-enced by TDI diesels. As counsel for Suffolk County in the licensing proceedings for the Shoreham plant, we recently obtained information which may have significant safety and other implica-tions for the TDI diesels _at Shoreham. That information, which is detailed and documented in the attached memorandum, indicates that the NRC Staff Region 1 inspectors who conducted an inspection on July 28-29, 1983 of a sampling of replacement cylinder heads to be installed in the TDI diesel generators at Shoreham based their findings of no violations or nonconformances upon incorrect and invalid information. See Inspection Report No. 50-322/83-25 (the

" Inspection Report").

First, a cracked cylinder head was accepted at Shoreham because TDI informed the NRC inspectors that TDI's established criterion is to accept cracked heads if they pass a hydrostatic test without leaking. In fact, TDI's quality assurance documents do not provide that cracked cylinder heads are acceptable.

Second, the NRC inspectors used invalid standards for accept-able firedeck wall thickness in cylinder heads, and accepted a non-existent " engineering disposition" to justify a minimum wall thickness below the apparent specification.

8402080167 840203 PDR ADOCK 05000322

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s HEREFATRICK, IACEMART, HarA, CumteroPunu & PHIIAIPS Mr. Harold R. Denton February 3, 1984 Page 2 It is now clea;.that the findings of the Inspection Report are incorrect and that inadequate and deficient replacement.cyl-

/ inder heads are installed in the Shoreham diesels. Apparently, the only inspection of replacement cylinder heads made since July was the hydrostatic testing of two heads by LILCO in October 1983.

LILCO's consultant, Failure Analysis Associates, noted corrosion of the cylinder liner in cylinders of two Shoreham diesels, but

.apparently did not inspect the cylinder heads for cracks or other defects.

In view of the foregoing, Suffolk County hereby requests that the NRC Staff promptly undertake a complete inspection of each of the 24 cylinder heads installed in the three Shoreham diesels, as well as any cpare cylinder heads onsite, to determine whether or not they comply fully with all applicable standards. Those stan-dards should be fully. justified by appropriate engineering and design documentation _that complies with NRC regulatory require-ments.

Because of the significance of these matters, copies of this letter and the accompanying memorandum are being sent to the Licensing Board, all parties, TDI and others on the service list.

,Very truly yours, Alan Roy nner ARD/dk Enclosure cc: Service List Edward G. Greenman

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EImrPATRICE, LOCKHART, HILL, CHRISTOPHER & PnILLIPs A PAmsnmente IncLenano A Peormassonat ConFORATION 1900 M Srnmar, N. W WASHINO1ux, D. C. 20006 Tatarpoows (ace) me.rooO Is PrTTsavnen cassJt WIFEtt 33mEFATRK1, LAM 3 MART.J0EEe0N & kt1Cli1 SON TaLas 4eosos narut Ut 1500 osJvna ar113ING wartan's asusCT DIAL NVEREBE FITTEDCEOH, PENNNYLVANIA 36899 (es) ass esco

-MEMOR

- - - - .A N D U M-----

February 3, 1984 RE: NRC Region 1 Inspection Report No. 50-322/83-25:

Replacement Cylinder Heads at Shoreham By letter dated August 15, 1983, NRC Region 1 transmitted to LILCO the subject Inspection Report concerning the inspection on July 28-29, 1983, of replacement cylinder heads manufactured by Transamerica Delaval, Inc. ("TDI") to be installed in the emer-gency diesel generators at Shoreham. A copy of that letter and Inspection Report are attached as Exhibit A.

By letter of August 23, 1983 (attached as Exhibit B), Suffo]k County requested production of certain documents referred to in the Inspection Report on which NRC Staff findings were based.

TDI, by its counsel, finally responded to these requests by letter of January 24, 1984 (attached as Exhibit C). That response estab-lishes that the Region 1 inspectors relied upon incorrect and invalid information to justify their conclusions.

1. Cracked Cylinder Head; Incorrect Acceptance Standard.

NRC inspectors visually inspected 13 TDI cylinder heads, using TDI

4 KIRKPATRICN, LOCMMART, HILL, CHMISTOPHEN & PHutt.rPs MEMORANDUM February 3, 1984 Page 2 QA procedure 600-10, Addendum A, Visual Inspection Procedure.

Presumably all cylinder heads had been previously inspected

visually by TDI under this procedure and by LILCO under its QA program. The NRC inspectors found a 3/8 inch long " indication,"

or crack, in one cylinder head, and noted in the Inspection Report that the cracked head was unacceptable under the TDI Visual Inspection Procedure.

However, TDI then was permitted to evaluate the cracked head.

TDI informed the.NRC inspectors that under TDI's " acceptance-rejection criteria established by [TDI] Engineering," cracks are acceptable so long as they do not leak under hydrostatic testing.

Suffolk County requested production of TDI documents which estab-lish that criterion (see Exhibit B). TDI's response (see Exhibit C) was.its Hydrostatic Testing Procedure, 600-70, Rev. 3 (attached as Exhibit D), with particular reference to paragraph 3.5.4. That provision merely states that if a component leaks during testing, the leaks will be repaired. Nothing in this Procedure sugaests j that components known to be cracked and unacceptable under TDI's Visual Inspection Procedure will nevertheless be acceptable if they do not leak under hydrostatic testing. Because TDI's re-sponse for documents, after some five months, purports to be accurate and complete, it must concluded that there are no TDI

EtaEFATRICE, IACEMART, Han, Cuassrorumm & Putuurs MEMORANDUM February 3, 1984 Page 3 documents which support the information given to the NRC inspec-tors, and that such information was incorrect.

In addition, if TDI's QA program had permitted cracked cylinder heads to be installed in emergency diesel engines at Shoreham, the NRC Staff should have questioned whether such QA standards are proper and justified. Apparently the Staff did not make any such' inquiry or seek engineering and design justifi-cation. They simply allowed a cracked cylinder head to be installed at.a nuclear power plant because TDI said that was acceptable.

2. Firedeck Wall Thickness; Unjustified Acceptance Stan-dards. The NRC inspectors examined the firedeck wall thickness of thirteen cylinder heads, finding variances in thickness ranging from 0.464 inch to 0.881 inch. The Inspection Report (para.

2.2.b) states that the firedeck wall thickness " acceptance stan-dard was 0.500 inch +j.005 inch instrument accuracy and + . 010 inch per applicable drawings," and that " nominal firedeck thick-

, -ness is specified as 0.500 inch." There is no explanation in the Inspection Report as to why the inspectors did not view as unac-ceptable the large number of thickness readings which exceeded the maximum firedeck thickness.

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KiBEFATRICK, LOCMMART, Han, CuRusroenna & Putt.r,tes

. MEMORANDUM February 3, 1984 Page 4, In response to the County's request for " documents which establish the acceptance standard (s) for the thickness of the Delaval cylinder head firedeck wall" (see Exhibit B), TDI stated:

The acceptance standard was established by Inspection Report 00783 which you already have. That report is the only responsive document.

See Exhibit C (emphasis added). The referenced report is a single

. page TDI inspection report, dated February 21, 1981, covering the inspection of four cylinder heads. A copy of TDI inspection report 00783 is attached as Exhibit E. The TDI inspection report contains no detailed specifications or acceptance standards for firedeck wall thickness of cylinder heads. It shows only the following:

a. Under the heading " Description of De'.riation" there is set forth the thickness of the firedecks of 4 cylinder heads measured by ultrasonic test (U.T.) at four unspecified points.

I The thickness ranges from 0.420 inch to 0.768 inch,

b. Under the heading "Cause" are the words " Core Shift."

l l Presumably this indicates that the large variances in firedeck thickness were caused by a core shift in the molds during the casting process.

c. Under the heading " Comments" opposite the initials "ENG" there is written " Functionally Acceptable (.400 Min. Tolerance)."

8

- The comments section is signed by R. A. Pratt and dated 2/21/81.

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KINEPATHICK, LocxHART, UILL, CHNINTOPHEn & PHILLIPS MEMORANDUM February 3, 1984 Page 5 On its face, then, the TDI inspection report 00783 appears to be merely an unexplained waiver by Mr. Pratt for the engineering section of TDI of the specified minimum firedeck thickness of 0.490 inch (0.500 inch - .010 inch) for four particular cylinder heads which were out of specification because of a core shift.

However, TDI has interpreted this single inspection report as the only document which establishes the acceptance standards for the thickness of the firedeck wall. This means that TDI has no standards for maximum firedeck wall thickness, and a minimum thickness standard of 0.400 inch.

The NRC Inspection Report thu; incorrectly states:

The nominal firedeck thickness is specified as 0.500 inch. However, the Engineering Department of TDI has set down as policy, via TCI (sic) inspection report No. Q0783, that 0.433 inches shall be the minimum acceptable thickness.

S.ince the readings (of firedeck wall thickness taken by the NRC inspectors] do not fall below this minimum, they are considered acceptable.

Exhibit A, para. 2.2.b. This statement is incorrect because, according to TDI, there is no nominal specified firedeck wall acceptance criterion other than as stated in TDI inspection report 00783, that criterion is a minimum of 0.400 inch, not 0.433 inch, and there is no evidence that inspection report 00783 states the

" policy" of TDI for the production of all cylinder heads. The

KINEPATERICK, IABCMuART, Harz, Cumistornam & Puin.t.rra

. MEMORANDUM February 3, 1984 Page 6 reliance by the NRC inspectors on TDI inspection report 00783 for their inspection findings is inexplicable.

In.its letter transmitting the NRC Inspection Report (Exhibit A), the Staff states:

Further discussions with Mr. J. Kammeyer on August 12, 1983, provided information that the engineering acceptance criterion for engine firedeck wall thickness was established as 0.400 inches in an engi-neering disposition dated February 22, 1981, regarding a quality control finding of a thickness of 0.433 inches on head 4 A2.

Exhibit A, letter at 1. TDI's response (Exhibit C) to the l County's request for that " engineering disposition dated February 22, 1981" is that no such document exists. Thus, Mr. Kammeyer of i

i Stone & Webster Engineering Company, which works for LILCO, furn-ished incorrect information to the Staff. We do not know why the Staff relied upon that information without obtaining a copy of the alleged " engineering disposition."

Immediately after receipt of the NRC Inspection Report, an attorney for Suffolk County, Mr. Alan Dynner, telephoned Mr.

Edward Greenman of NRC Region 1 to discuss the acceptance of the cracked cylinder head and the standards for firedeck wall thick-l ness. Mr. Greenman stated that he believed the NRC inspectors had reviewed documents which adequately supported their findings, but that such documents were no longer in the possession of the Staff.

KInuPATHIcx, LocxHART, IIILL, CHNIMTOPHER & PHILLIPH MEMORANDUM February 3, 1984 Page 7 This prompted the County's request for production of documents (Exhibit B).

As discussed above, TDI's response (Exhibit C) demonstrates that there are no documents which justify acceptance of a cracked cylinder head. The County also requested production of all engineering analyses, reports, evalu-ations or other documents regarding the justification for applying a minimum acceptable firedeck thickness of less than 0.500 inch.

Exhibit B, para. 2.

TDI's response states that aside from TDI inspection report 00783 (Exhibit E), "there are no additional documents responsive to this request." (Emphasis added). This indicates that Mr.

Pratt's waiver of defects in four cylinder heads in February 1981 became the general TDI acceptance criterion with no analyses of the effect of the lower minimum thickness standard or the absence of a maximum thickness standard upon the design and manufacture of TDI cylinder heads. This probably violates applicable NRC regu-lations in 10 C.F.R Part 50, Appendix A and Appendix B.

In conclusion, it is clear that the NRC Inspection Report contains faulty conclusions based upon incorrect and invalid in-formation. The replacement cylinder heads installed at Shoreham The County received inspection report 00783 in early October 1983 from LILCO. The County then assumed that there must be other documents. The response from TDI was not given until its letter of January 24, 1984 (Exhibit C).

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ I

KHxPATHICM, LOCKIIANT, IllLL, C11HIHTOPHER & Pn LLIPs MEMORANDUM February 3, 1984 Page 8 include at least one cracked cylinder head and at least eight cylinder heads having firedeck wall.s both thinner and thicker than permitted by a specification of 0.500 inch + .010 inch. These matters may have significant safety significance and, in addition, potentially entail the furnishing of false or misleading inform-ation to the NRC Staff and questionable inspection procedures and conclusions by the Staff.

ggg UNIT :D STATES EXHIBIT A

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o NUCLEAR REGULATORY COMMisslON y ,( g REGION I I

$ - g 831 PARK AVENUE KING OF PRUSSI A. PENNSYLVANIA 19408 k g . . . . . ,o AUG 15 1983 i

Oocket No. 50-322 Long Island Lighting Company ATTN: Mr. M. S. Pollock Vice President - Nuclear -

175 East Old Country Road Hicksville, NY 11801 Gentlemen:

i

Subject:

Inspection No. 50-322/83-25 i This refers to the special safety inspection conducted by Mr. Richard Harris of

, this office on July 28 and 29,1983, at Shoreham Nuclear Power Station of activities authorized by NRC License No. CPPR-95 and to the discussions of our i findings held by Mr. Harris with Mr. R. Purcell of your staff at the conclusion 1

of the inspection.

Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and. representative records, interviews with personnel, measurements made by the inspector, and cbservations by the inspector.

Within the scope of the inspection, no violations were observed.

Information contained within the enclosed inspection report has been discussed with Mr. Youngling of your staff by telephone on August 12, 1983. During this discussion, it was concluded that the inspection report contained no informa-

tion that you considered proprietary; therefore a copy of this letter and its enclosures are being placed in the NRC's Public Document Room.

i Further discussions with Mr. J. Kammeyer on August 12, 1983, provided informa-tion that the engineering acceptance criterion for engine firedeck wall thickness was established as 0.400 inches in an engineering disposition dated February 22, 1981, regarding a quality control finding of a thickness of 0.433 inches on head A2. This criterion was then applied to other heads, specifically, the G and H series heads which were the object of this inspection.

t' D 5

Long Island Lighting Company 2

No reply to this letter is required. Your cooperation with us in this matter is appreciated.

Sincerely, O 4</

Thomas T. Martin, Director Division of Engineering and Technical Programs

Enclosure:

NRC Region I Inspection Report No. 50-322/83-25 cc w/ encl:

J. Rivello, Plant Manager J. L. Smith, Manager of Special Projects Director, Power Division Edward M. Barrett, Esq. '

Jeffrey L. Futter, Esq.

T. F. Gerecke, Manager, QA Department Shoreham Hearing Service List - '

Public Document Room (PDR) local Pubite Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York O

. . , . ~ , - , , . . , . - - , - , . , - - . --- - - , - , - - , - - - - , . -

U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-322/83-25 Docket No. 50-322 License No. CPPR-95 Priority --

Category B Licensee: Long Island Lighting Comoany 175 East Old Country Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear power Plant Inspection At: Shoreham, New York Inspection Conducted: July 28-29, 1983

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Inspector .

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NDE Technician M////S da'te /

244 Randy . Campbell,jf4RC Technician 6ks dath /

Approved by: MN T 1e

l. P. Durr, Chief, Materials and Processes FM D date Section Insoection Summary: Insoection on July 28-29, 1983 (Report No. 50-322/83-25)

Areas Insoected: A routine, announceo NRC independent inspection by two NRC regional based (NDE) nondestructive examination technicians. The inspection utilized ten onsite hours to conduct NDE on diesel generator replacement cylinder heads.

An independent nondestructive examination (NDE) was conducted at the site utilizing the liquid penetrant, color contrast, dry developer method, a thickness examination utili::ing a Nortec 124 thickness measuring instrument, and visual examination.

Results:

No violations were identified.

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CETAILS 1.0 Persons Contacted Long Island Lighting Comoany (LILCo) 4

• A. Mullen, OQAE

• J. G. Wynne, TSC "R. Purcell, Assistant Startup Manager "J. J. McCarthy, Section Supervisor "G. J. Gisonda, Licensing Engineer

• W. R. Klein, LSE

• D. Terry, Chief Maintenance Engineer "M. H. Seluster, Welding Supervisor "R. J. Bennardo, 00A Inspector

• E. J. Nicholas, Section Supervisor ,

• N. C. Irvine, NDE Level III

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• C. K. Seaman, Senior Project Engineer J. Smith, Licensing

• A. Dobrzeniecki, LSU U.S. Nuclear Regulatory Commission J. C. Higgins, Senior Resident Inspector

• R. H. Harris, NDE Technician

• R. M. Campbell, NRC Technician "J. P. Durr, Chief, M&PS

• H. Nicholas, Lead Reactor Engineer

• Denotes attendance at exit meeting.

2.0 Indeoendent Measurements - NRC Nondestructive Examinations (NDE)

An.onsite independent nondestructive examination (NDE) was conducted at the site on July 28 and 29, 1983. This inspection was conducted by-regional based NDE personnel.

The purpose of this examination was to determine the ad2quacy of licen-see's quality control program on incoming vendor supplied equipment. This was accomplished by performing a visual, thickness and liquid penetrant examination of the material selected. Selected for inspection were 13 Standby Diesel Generator Cylinder Heads received for replacement of present heads.

2.2 Nondestructive Examinations Examinations were performed using NRC procedures and those submitted by the licensee's vendor, Transamerican Delaval, Incorporated (TDI).

The following examinations were performed:

F 3

a.Liould penetrant Examinations Three Diesel Generator Heads were examined per NRC procedure NDE 9, Rev.

O. Areas inspected by the liquid penetrant method were as follows.

Diesel Generator Head S/N Area G-95 Three valve seat araas E-71 Four valve seat areas H-56 Two valve seat areas A total of nine valve seat areas were inspected.

Results Eight areas inspected had no apparent indications. One area had a linear indication of approximately six inches with minimal bleed out at an area where the stellite interfaces with the base material. Further investi-gation revealed this to be a nonrelevant indication created by machining.

b. Thickness Measurements Thirteen Diesel Generator Heads were examined using a Nortec'124 digital thickness gauge. Areas examined for thickness were in the Cylinder Head firedeck wall. Readings were taken on final machined finish. The accep-tance standard was 0.500 inch .005 inch instrument accuracy and .010 inch per applicable drawings.

Results All readings of 0.485 inch and below were recorded and noted for the following Cylinder Heads (as noted on attachments).

Diesel Generator Heads SN Area Reading, inches G-19 3 .483 l

G-56 1&2 .478/.469 H-67 3 .485 G-52 3 .464 H-60 3 .479 l G-53 3 .484 G-89 3 .485 H-34 2&3 .485/460 The nominal firedeck thickness is specified as 0.500 inch. However, the Engineering Department of TDI has set down as policy, via TC1 inspection report No. Q0783, that 0.433 inches shall be the minimum acceptable thickness. Since the readings listed do not fall below this minimum, they are considered acceptable.

i

4

c. Visual Insoection Thirteen Diese' Generator Cylinder Heads were visually inspected per Delaval procedure 600-10, Addendum A, Visual Inspection Procedure.

Listed below are the 13 Diesel Generator Cylinder Heads selected by NRC resident for inspection.

Serial Numbers G-95 H-60 E-71 G-53 H-56 G-89 G-19 H-34 G-56 H-11 H-76 H-67 G-52 Results Diesel Generator Head ?/N H-34 has an indication approximately 3/8 inch in length on the machined face bottom port area. This indication is unacceptable in accordance with Delaval Visual Inspection Procedure 600-10, Addendum A paragraph 4.

The indication found on this head was evaluated by the TDI Quality Control Supervisor and Engineering Department. The acceptance-rejection criteria for machined peripheral surfaces is that the surface does not leak under Hydro-test. The indication did not result in a leak. Therefore it was in conformance with the acceptance-rejection criteria established by Engi-neering. This information was provided by TDI Engineering.

d. Attachments Attached to this report are field sketches showing locations of UT thick-ness measurements and one indication as discussed above.

3. Exit Interview At the conclusion of the inspection, an exit interview was held with licensee representatives noted in paragraph 1 on July 29, 1983. No written material was given to the licensee in the course of this inspec-tion.

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EXHIBIT B huw=xrarcx, Loewm=T, Hrnr., CwnraTornza Be ParLLIPs e A PA Im:smosso A Paarmessaums. Consemarnas 1900 M STREET, N. W.

WAsuzxoTow, D. C. 20o06 I

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.aoussar a senzzsor 2==**==*====x ou == nexxmino wur=== . - =.r. ==== August 23, 1983 ==.c=.m. r===.minu

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202/452-7044 -

T. S. Ellis, Esq.

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 Re:. Request for Discovery Concerning NRC Region I Inspection Report No.

50-322/83-25

Dear Tim:

Suffolk County believes that the referenced Report may identify significant deficiencies in the "new-style" cylinder heads produced by Delaval and. purchased by LILCo for installa-tion in the Shoreham emergency diesel generators. We have discussed the Report with NRC Staff personnel, and they do not have copies of certain documents upon which the conclusions in the Report are based. Because of the significance of these matters and their relevance to the County's contention regarding the cracking of cylinder heads, we request production of copies of the following on an expedited basis:

1. Documents which establish the acceptance standard (s) for the thickness of the Delaval cylinder head firedeck wall.

(See para. 2.2.b of the Report).

2. The Delaval " inspection report No. 00783," setting forth policy "that 0.433 inches shall be the minimum acceptable thickness" of the firedeck (see para. 2.2.b of the Report), and any other documents which establish a minimum acceptable firedeck thickness of less than 0.500 inch, including the " engineering disposition dated February 22, 1981, regarding a quality control finding of a thickness of 0.433 inches on head A2," all documents applying that criterion to the Delaval heads acquired by LILCO, and all engineering analyses,. reports, evaluations or other documents regarding the justification for applying a minimum acceptable

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Krumpararcx,Icew=An, Hu.L, CamroTorumm & Puzz.LrPS T. S. Ellis, Esq.

August 23, 1983 Page 2 8

firedeckthdeknessoflessthan0.500 inch (see Region I letter of August 15, 1983, transmitting the Report to LILCO) .

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3. Documents which establish that Delavals " acceptance-rejection criteria (sic) for machined peripheral surfaces (of cylinder heads) is that the surface does not leak under Hydro-test." (See para. 2.2.c of the Report).

Very truly yours, Alan Roy Dynner ARD/dk . .. . . . - - . . _

cc: Richard J. Goddard, Esq.

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, . EXHIBIT C GUGGENHEIMER & UNTERMYER 80 PIN E STREET, New Yonn. N.Y. LOO o S casta nooness urunoucue new ve==

TELEM ala6278 TW M - 7 t O- S e a -2 7t e TELEPHONE (212) 344-2040 orx-daoo TELEcoPv (ataa n43-34s3 January 24, 1984 Alan R. Dynner, Esq.

Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N. W.

Washington, D. C. 20036 Re: Diesel Generator Discovery -

Cylinder Head Issue

Dear Alan:

On behalf of Transamerica Delaval Inc., I respond to your outstanding requests for documents in connection with the cylinder. head contention.

With Respect to Your Letter Dated August 23, 1983 Item 1. The acceptance standard was established by Inspection Report 00783 which you already have. That report is the only responsive document.

Item 2. There are no additional documents responsive to this request. Furthermore, we do not believe that there is any engineering disposition dated February 22, 1981 regarding the acceptance standard. Instead, we refer to the engineering disposition, dated February 21, 1981, signed by R. A. Pratt shown on 00783.

Item 3. In response to this item, we enclose Nondestructive Examination Procedure 600-70 entitled " Hydro-static Testing". We direct your attention specifically to ,

paragraph 3.5.4. l With Respect to Your Letter Dated September 14, 1983 Item 1. The QA manual used for the new style cylinder heads is entitled "ASME Quality Assurance Program" which replaced IP500. Copies of both are enclosed.

Item 2. The QA manual used for the old style heads was entitled " Quality Assurance Manual", a copy of which is enclosed. We also enclose copies of I.P. 100 through 600.

. Alan R. Dynner, Esq. January 24, 1984 Item 3. The " objective evidence" referred to in the " comments" section of the Audit Evaluation Form for the audits of October 28-30, 1975, February 23, 1976 and June 18, 1976 refers to evidence in the possession of Stone & Webster Engineering Corporation which serves as a consultant to Lilco.

.Accordingly, such information should be sought from Lilco.

There are no further remaining documents under Item 3 not supplied to you.

Item 4. There are no such documents.

Sincerely yours, a

l d t )

Robert E. Smith RES/vp

-Enclosures cc: T. S. Ellis, III, Esq.

. U8I8 val -

EXHIBIT D NONUESTRUCTIVEEXAM5NAT10NPROCEDURE TITLE Nydrostatic Testing NUMBER 600-70 REVISION 3 DATE October 24, 1980 PREPARED BY D.R. Cady APPROVED FOR USE

$ $ hy tA.-

QUAllTY ASSURANCE MANAGER bawl.. W NDE LEVEL ilI -

1.0 Scope l.1 Method 1.1.1 This method of inspection covers the application of internal .

hydrostatic pressure to welded assemblies and cast products for hydrostatic leak testing.

1.2 Authorization l.2.1 Hydrostatic testing shall be applied only when such coverage is designated in the contract Specifications. The assemblies to be tested and the pressure required shall be specified on shop drawings and/or route sheets.

2.0 Equipment and Materials 2.1 Liquid Media 2.1.1 Water supplied by Public Service Company shall be used for testing unless otherwise specified.

2.2 Ptnp 2.2.1 A commercial type pump shall be used which has the necessary pressure rating.

I 2.3 Gauges 2.3.1 Indicating pressure gauges shall have a dial graduated over a range at least 1-1/2 times the test pressure but not more '

than 4 times the test pressure.

2.3.2 All gauges shall be calibrated against a periodically calib-rated (6 nontns) master gauge prior to each test or series of tests. ,

2.3.3 A recording gauge shall be used when required by contract specifications.

2.4 Necessary saddles or supporting devices will be provided.

2.5 Miscellaneous Equipment 2.5.1 Hoses, valves, venting, plugs, blank flanges, gaskets and bolts as required. ,

2.6 Determine test pressure and any special contractural requirements (such as unusual support blocking) from construction prints.

I

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1. -27./d 4ked. #46 -J- l Hydrostatic Testing .

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1. 77 B / C'. - SPECmCAUoN

• a -t M C' / E f l ENGINE AND DIVislON COMPRESSOR

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55o _ ssin avents 600-70 DATE CHECMED APPR OVE D ALTE R ATIONS Fnera G 26618 8) S/?? Fey Quasety Contros

30 Test Applicatien 31 component kephratien 3 1.1 All joints including welds shall be left uninsulated and -

exposed. Ibzzles and fittings slall ba blanked off with prcper test plugs, covers and/or bolts. Vessel shall be top vented for filling with water. Two test gauges shall be '

mounted in positions allowirg them to be readily seen dur-ing pressure application to insure against over pressure.

32 Test Temperature 3 2.1 Test shall be perfomed at a temperature which will minimize the possibility of brittle fracture in accordance with Sec-ification requirements and/or applicable codes.

3.2.2 Component and test media shall be at approximately the same temperature prior to application of test pressure.

- 3 3 Test Pressure 3.3 1 Test pressure shall be 11/2 times the design pressure unless otherwise indicated in the @ecifications.

3.4 Preliminary Inspection

( 3.4.1 The test pressure for the preltninary inspection shall be the greater of the design pressure or 3/4 the test pressure.

3.4.2 Pressure will be maintained for a minimum of ten (10) ,

minutes at which time a preliminary surface inspection will be performed.

3.5 Final Test 3.5.1 ABS and API components shall be brcught to full test pressure and left to stand for a mindmn of one hour, prior to exami-nation.

t 3 5 .'2 AS4E Section III Class III and ANSI E31.1 components shall be brought to full test pressure and left to stand for a minimum of 10 minutes prior to examinition.

3 5.3 After tester has cleared final pressure test, the entire vessel will be thoroughly inspected.

3 5.4 Any leaks found during this testing will be repaired as indi-cated in the Standard W1d Repair Procedure and as provided for by the @ecifications and/or applicable codes, I PAGE 2 f

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% "estatic Testing

1. t-77 42 # v. ESIf3 -

lu ENGINE AND SPECW N

E COMPRESSOR DIVISION 550 - 85th AVENUE 600-70 DATE CHECKED APPaovtD ALTERATIONS Fiwm 0-264 (# H S/72 Fev. Quamy Comros

I 3 . F 3 5.4.1 Repaired ccrmen:nts sin 11 te re-tcsted as outlined in this procedure.

4.0 Doctznentation ,

h.1 Test reconis will be maintained by the manufacturer and/or sub-mitted to the purchaser based on contract agreement.

4.2 The Hydrostatic Test Report shall contain the following information:

4.2.1 Part identification and area to be tested.

4.2.2 Test Pressure requirements 4.2 3 Duration of Test 4.2.4 Per:on performing the test 4.2.5 Quality control verification of test and acceptance.

4.2.6 Procedure and revision number being used.

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/e.Jr/s .dW' C SG - J' - l Itidrostatic Testing

• ( 77 4#C MRP *E-E ENGINE AND SPECIF ^

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COMPRESSOR DIVISION 550 - 85th AVENUE DATE cMEcKED Apemovto ALTE R ATeoNS ,

rka o. ass (n 1) Snr rey. owenty conieos

iransamenca Delaval

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l HYDROSTATIC TEST REPORT l ..

PART IDENTIFICATION DATE

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PART NLMBER JOB NLNBER QlMNITY SERIAL NLNBER PROCEDURE REV.

TEST PRESSURE DURATION AREA TESTED PRESSURE GAGE SERIAL to.

NOTATIONS:

I TEST OPERATOR TEST SUPERVISOR QlRLITY CONTROL ACCEPTANCE DATE INSPECTOR NDE FORM 600-70 10/80 page 4 of4

T (EXHIBIT E) usE oALL FOiNT PEN 3.EO

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