ML20087G412
| ML20087G412 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/19/1984 |
| From: | Carr A BISHOP, COOK, PURCELL & REYNOLDS, DUKE POWER CO. |
| To: | CAROLINA ENVIRONMENTAL STUDY GROUP |
| References | |
| NUDOCS 8403200007 | |
| Download: ML20087G412 (21) | |
Text
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t *~ RELATED cme;?O::DENCE 4
00LMETEr U9PC UNITED STATES OF AMERICA 84 MR 19 A9:32 NUCLEAR REGULATORY COMMISSION CFFILE C' -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARDOCKETING I S[N;l t 3 RANCH I' In the Matter of )
i }
DUKE POWER COMPANY, --
et al. -) Docket Nos. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE DOCUMENTS TO CAROLINA ENVIRONMENTAL
- STUDY GROUP AND PAIJiETTO ALLIANCE ON BOARD CONTENTION CONCERNING CERTAIN DIESEL GENERATOR PROBLEMS I Pursuant to 10 C.F.R. (( 2.740b and 2.741 and in accordance with the Licensing Board's Order dated February 27, 1984, and the expedited hearing schedule established by the Board contained therein, Duke Power Company, et al. (" Applicants") hereby serve Applicants' Interrogatories and Requests to Produce on the Board j Contention Concerning Certain Diesel Generator Problems upon Intervenors, Carolina Environmental Study Group (CESG) and Palmetto Alliance (PA). These interrogatories involve.the Board i contention on reliability of the Catawba diesel generators in light of problems which Applicants have reported to the Board.
Each interrogatory shall be answered in writing, under oath or affirmation, and include all pertinent information known to
.CESG or PA, their officers, directors or members as well as any pertinent information known to their employees, advisors or
) counsel. Each request to produce applies to pertinent documents 8403200007 840319 P PDR ADOCK 05000413 >
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which are in the possession, custody or control of CESG or PA, their officers, directors or members as well as their employees, advisors or counsel. In answering each interrogatory and responding to each request, please recite the interrogatory or i
request preceding each answer or response. Also, please identify i
the person providing each answer or responsa.
These interrogatories and requests shall be continuing in nature. Thus, any time CESG or PA obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, CESG or PA should supplement its previous response to the appropriate interrogatory or request to produce. CESG or PA should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject
- matter of his or her testimony, and the substance of that
- testimony. Applicants are particularly interested in the names and areas of expertise of CESG's or PA's witnesses, if any. Each identification of such witnesses is necessary if Applicants are to be afforded adequate time to depose them.
The term " document" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained. We request that at a date or dates to be agreed upon, CE3G or PA make . available for inspection and copying, all documents subject to the requests set forth, below.
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REQUESTS FOR DOCUMENTS Pursuant to 10 C.F.R. $ 2.741, Applicants request CESG and PA by and through their attorneys to make available for inspection and copying at a time and location to be designated, any and all documents, of whatscever description, identified in the responses to the Applicants' interrogatories below, including but not limited to:
(1) any written record of any oral communication between or among Intervenors, their advisors, consultants, agents, attorneys and/or any other persons, including but not limited to the NRC Staff, the Applicants and their advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of Whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.
If CESG or PA maintains some documents should not be made available for inspection, it should specify the documents and explain why such are not being made available. This request extends to any such document, described above, in the possession of CESG or PA, its advisors, consultants, agents or attorneys.
INTERROGATORIES Pursuant to 10 C.F.R. $ 2.740b, the Applicants request CESG or PA, by and through its attorneys, to answer separately and fully in writing under oath or affirmation, by persons having knowledge of the information requested, the following general and specific interrogatories.
A. General Interrogatories The following interrogatories apply to the diesel generator contention admitted as an issue in controversy in this proceeding
- 1. Please state the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof he or she answered.
- 2. Please identify each and every pepson whom you are considering to call as a witness at the hearing in this matter on this contention, and with respect to each such person, please:
- a. State the substanceLof the facts and ,
l opinions to which the witness is l 1
expected to testify; . I
- b. Give a summary of the grounds for each opinion and
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- c. Describe the witness' educational and professional background.
- 3. Is your position on the contention based on-one or more calculations? If so
- a. Describe each calculation and identify any document setting forth such calculation,
- b. Who performed each calculation?
- c. When was each calculation performed?
- d. Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data.
- e. What are the results of each calculation?
- f. Explain in detail how each calculation provides a basis for the contention.
- 4. Is your position on the contention based on one or more experiments or tests? If so:
- a. Describe each experiment or test and identify any document setting forth such experiment or test..
- b. Who performed each experiment.or. test?
- c. When was such experiment or test performed?
-d. Describe each parameter or variable measured in such experiment or test.
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- e. What are the results of each experiment or test?
- f. Explain in detail how each experiment or test provides a basis for the contention.
- 5. Is your position on the contention based upon conversations, consultations, correspondence or any other type of communication with one or more individuals? If so,
- a. Identify by name and address each such individual.
- b. State the educational and professional background of each such individual, including occupation and institutional affiliations.
- c. Describe the nature of each ,
communication with such individual, when it occurred, and identify all other individuals involved.
- d. Describe the information received from such individuals and explain how it provides a basis for the issue.
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- e. Identify each letter, memorandum, tape, note or other record related to each conversation, consultation, correspondence, or other communication with such individual.
- 6. Is your position on the contention based upon one or more NRC Staff documents? If so, please identify such documents and make them available for inspection and copying.
B. Specific. Interrogatories Questions 1 to 58 are directed to the Transamerica Delaval, I
Inc. ("TDI") DSRV-16-4 model diesel generators installed at Catawba.
- 1. What is the lube oil prelube line?
- 2. What is the function of the lube oil prelube line?
- 3. When is the lube oil prelube line in operation?
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- 4. What caused the lube oil prelube line to fail?
- 5. What fixes or modifications do you believe should be undertaken for the lube oil prelube line and why?
4 Describe each such fix or modification in detail and i
provide the basis for your conclusion.
- 6. What is the effect of the rupture of the lube oil .
prelube line on the operation of the Catawba' diesel generator?
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- 7. What is the effect of the rupture of the lube oil i l prelube line on the operation of the Catawba d ese Do you believe such a generator during an emergency?
failure would prevent the diesel generator from
? If porforming its requisite task during an emergency diesel so, explain how such a failure would prevent the generator from performing its task during an emergency and provide bases for your conclusion.
What failures, if any, of lube oil prelube lines on
- 8. h other TDI diesel generators are applicable to t e State the basis for your Catawba diesel generators?
belief as to such applicability. 100%
9 Does a trial run of a specified number of hours at load without a failure of the lube oil prelube line If your demonstrate that this problem has been solved?
state pnd explain the basis answer is in the negative, for your conclusion.
If your answer is in the affirmative, state the time limit, if any, you believe is necessary to demonstrate the reliabilty of the lube oil prelube line and explain the bases of such - time limit.
10.
What is the turbocharger lube oil drain line?
drain 11.
What is.the function of the turbocharger lube oil line?
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- 12. When is the turbocharger lube oil drain line in operation?
- 13. What caused the turbocharger lube oil drain line to leak?
- 14. What fixes or modifications do you believe should be undertaken for the turbocharger lube oil drain line and why? Describe each such fix or modification in detail and provide the basis for your conclusion.
- 15. What is the effect of the leakage from the turbocharger lube oil drain line on the operation of the Catawba diesel generator?
- 16. What is the effect of the leakage from the turbocharger lube oil drain line on the operation of the Catawba diesel generator during an emergency? Do you believe such a failure would prevent the diesel generator from performing its requisite task during an emergency? If so, explain how such a failure would prevent the diesel generator from performing its task during an emergency and provide bases for your conclusion.
- 17. What failures, if any, of the. turbocharger lube oil drain lines on other TDI diesel generators are applicable to the Catawba diesel generators? State the basis for your- belief as to such applicability.
- 18. Does a trial run of a specified number of hours at 100%
load without a failure of the turbocharger lube oil drain line demonstrate that this problem has been solved? If your answer is in the negative, state and explain the basis for your conclusion. If your answer is in the affirmative, state the time limit, if any, you believe is necessary to' demonstrate the reliability of the turbocharger lube oil drain line and explain the bases of such time limit.
- 19. What is the design relationship of the cylinder head and water jacket on the Catawba diesel generator?
- 20. What do you believe to be the cause of the cylinder head crack in the Catawba diesel generator?
- 21. What fixes or modifications do you believe should be undertaken for the Catawba diesel generator cylinder head? Describe each such fix or modification in detail and provide the basis-for your conclusion.
- 22. Given a jacket water leakage rate of approximately 5 gallons / day, what is the effect of the cylinder head crack on the operation of the Catawba diesel generator?
- 23. Given a jacket water leakage rate of approximately 5 gallons / day, what is the effect of the cylinder head crack on the operation of the Catawba diesel generator during an emergency? Do you believe such a failure would prevent the diesel generator from performing its l
requisite task during an emergency? If so, explain how such a failure would prevent the diesel generator from performing its task during an emergency and provide bases for your conclusion.
- 24. What cracking, if any, of cylinder heads at other TDI diesel generators is applicable to the Catawba diesel generator? State the basis for your belief as to such applicability.
- 25. Does a trial ~run of a specified number of hours at 100%
load without a failure of the cylinder head demonstrate that this problem has been solved? If your answer is in the negative, state and explain the basis for your conclusion. If your answer is in the affirmative, state the time limit, if any, you believe is necessary to demonstrate the reliability of the cylinder head and explain the bases of such time limit.
- 26. What is the fuel oil injection pump nozzle?
- 27. What is the function of the fuel oil injection pump nozzle?
- 28. When is the fuel oil injection pump in operation?
- 29. What caused the fuel oil injection pump nozzle to rupture?
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believe should be d
30 What fixes or modifications do youil injection pump nozz undertaken for the fuel o modification in detail why? Describe each such fix or your conclusion.
and provide the basis for of the fuel oil effect of the rupture 31 What is the h operation of the Catawba injection pump nozzle on t e diesel generator? upture of the fuel oil 32 What is the effect of the r ation of the Catawba injection pump nozzle emergency?
on the oper Do you believe enerator from diesel generator during anwould prevent If the diese such a failure sk during an emergency? l performing its requisite ta would prevent the diese failure so, explain how such a its task during an emergency generator from performing r conclusion.
and provide bases for youf fuel oil., injection pump What failures, if any, o are applicable to 33 l generators nozzles on other TDI dieseState the basis for your rator?
the Catawba diesel gene l y. 0%
belief in such applicabi t ified number of hours at 10 Does a trial run of a spec fuel oil injection pump 34.
solved?
load without a failure ofi any problem has been state and explain the nozzle demonstrate that tive th
, s If your answer is in the negaIf.your answer is in the basis for your conclusion. if any, you believe time limit, affirmative, state the l
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is necessary to demonstrate the reliabilty of the fuel oil injection pump nozzle and explain the bases of such time limit.
- 35. During an emergency situation, is it possible for the l diesel generator to continue to operate with the linkage to the ruptured injection pump disconnected and without detrimental effects to the diesel generator's operation?
If your answer is in the negative, state the basis for i
your conclusion. Do you believe such a failure would prevent the diesel generator from performing its requisite task during an emergency? If so, explain how such a failure would prevent the diesel generator from performing its task during an emergency and provide
'i bases for your conclusion.
1 36. What are the pushrods?
- 37. What is the function of the pushrods?
- 38. When are the pushrods in operation?
- 39. What caused the pushrods to have cracks in the. vicinity of the ball to tube . welded joint?
- 40. What fixes or modifications do you believe should be undertaken for the pushrod and why? Describe each such !
fix . or modification- in detail and provide the basis for your conclusion.
- 41. . What is the effect of the' crack in the pushrod on the operation of the Catawba diesel ~ generator? ,
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42.
What is the effect of the crack in the pushrod on the operation of the Catawba diesel generator during an emergency? Do you believe such a failure would prevent ii tasX the diesel generator from performing its requ s te If so, explain how such a failure during an emergency?
i its would prevent the diesel generator from perform ng task during an emergency and provide bases for your conclusion.
What failures, if any, of pushrods in other TDI diesel 43 generatoes are applicable to the Catawba diesel State the basis for your belief as to such generators?
applicability.
44.
Do you agree that the pushrod cracks are due to welding incompatibility between the pushrod ball and the pushrod tube?
do you contend
- a. If your answer is in the affirmative, that either welding standards or design ~ standards identify any such standards were violated? If so, which you believe are applicable and were violated.
Identify and specify with particularity the bases for your response, and explain in detail the bases for your response.
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- b. If your answer is in the negative, explain in detail the bases for your conclusion, citing any applicable design or welding standards and explaining why you believe any such standard should apply.
- 45. Given that the connector pushrods for which weld cracks develope ( consist of a tubular steel body fillet welded to carbon steel ball bearings, given that for pushrods of this design weld defects have resulted from lack of penetration of the fillet weld with the tubing, given that destructive examination of the ball and weld of such defective pushrod revealed additional cracks in the heat-affected-zone of the ball bearing, and given that the welds exhibited a lack of penetration and slag inclusions in the crevice area behind th'e weld, do you agree with the metallurgical conclusion that the ball material in such pushrods is difficult to weld? If your answer is in the negative, state and exlain the bases for your conclusion.
- 46. Given the design characteristics of the pushrods as described in question 45, do you agree that there is a design deficiency and that the design deficiency which has resulted in the cracked welds has been identified?
If your answer is in the negative, state the basis for
your conclusion and explain with particularity What you believe to be the design deficiency, if any, in the pushrods of such design.
- 47. Given a connector pushrod design ("new design")
consisting of a tubular steel shaft which is friction welded to cylinders of alloy steel on each end, following which such ends are machine finished and hardened, do you agree that pushrods of such design and fabrication will not be susceptible to the. weld cracking which has been experienced by pushrods of the design described in question 457 If your answer is in the negative, state the basis for your conclusion, explaining Why pushrods of such new design and fabrication are susceptible to such weld cracking.
- 48. Does a trial run of a specified number of hours at 100%
load without a failure of the pushpods demonstrate that the problem has been solved? If your answer is in the negative, state and explain the basis for your conclusion. If your answer is in tne affirmative, state the time limit, if any, you believe is necesary to demonstrate the reliability of the pushrods and explain the bases of such time limit.
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- 49. Do you agree that a decrease in turbocharger lube oil pressure when the diesel generator is operated under load is an indication of excessive bearing wear? If your answer is in the negative, state the basis for your conclusion.
- 50. What is the cause of excessive turbocharger bearing wear?
- 51. How is the turbocharger lubricated?
- 52. What would the effect of turbocharger bearing failure be on the operation of the Catawba diesel generator?
- 53. What would the effect of turbocharger bearing failure be on the operation of the Catawba diesel generator during an emergency? Do you believe such a failure would prevent the diesel generator from performing its requisite task during an emergency? If so, explain how such a failure would prevent the diesel generator from performing its task during an emergency and provide bases for your conclusion.
- 54. What failures, if any, of the turbocharger bearings in other TDI diesel generators are applicable to the Catawba diesel generators? State the basis for your bel'ief as to such applicability. !
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- 55. Does a . trial run of a specified number of hours at'1004 l
'1 load without a failure of the turbocharger _ bearing demonstrate that the problem'has been solved? HIf~your- l
l answer is in the negative, state and explain the basis for your conclusion. If your answer is in the affirmative, state the time limit, if any, you believe is necessary to demonstrate the reliability of the turbocharger bearings and explain the bases of such time limit.
- 56. What fixes or modifications do you believe should be undertaken for the turbocharger bearing lubrication system and why? Describe each such fix or modification in detail and provide the basis for your conclusion.
- 57. Do you agree that the diesel generator operability and reliability would not have been compromised by a turbocharger bearing failure? If your answer is in the negative, state the basis for your conclusion.
- 58. Given that the Catawba diesel generator dedicated loads during an emergency situation are ppproximately 75% of the diesel's load c'apability and given further that a normally aspirated diesel.(without turbocharger) can handle that 75% load, do you agree that the Catawba diesel generator dedicated loads during an emergency situation could be handled with either one or no i
k e
turbocharger functioning? If your answer is in the I
negative, state the basis for your conclusion.
4 Respectfully submitted, A -
J. Michael McGarry', GII Anne W. Cottingham Michael D. White BISHOP, LIBERMAN, CC '<
PURCELL & REYNOLDi 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9833 Albert V. Carr, Jr.
DUKE POWER COMPANY P.O. Box 33189 Charlotte, North Carolina 28242 (704) 373-2570 Attorneys for Duke Power Company, et al.
March 19, 1984
ET DCLK,p o .: E*
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0Fh a. U 3; p. .
BEFORE THE ATOMIC SAFETY AND LICENSING BOA dhpfC.
tho Matter of ) ;
)
2 POWER COMPANY, et al.
) Docket Nos. 50-413
) 50-414 it2Wba Nuclear Station, )
- nito 1 and 2) )
CERTIFICATE OF SERVICE I horeby certify that copies of " Applicants' Interrogatories i Requcats to Produce Documents to Carolina Environmental Study Jup and Palmetto Alliance on Board Contention Concerning itnin Diesel Generator Problems" in the above captioned matter a bacn served upon the following by deposit in the United itso mail this 19th' day of March, 1984.
nac L. Kelley, Chairman George E. Johnson, Esq.
3mic Snfety and Licensing Of fice of the Executive Legal Board Panel Director ;
- 3. Nuclear Regulatory U.S. Nuclear Regulatory
- ommiccion Commission ,
shington, D.C. 20555 Washington, D.C. 20555 l l
3 Paul W. Purdom Albert V. Carr, Jr., 5sq.
5 Columbia Drive Duke Power Company catur, Georgia 30030 P.O. Box 33189 Charlotte, North Carolina 28242 3 Richard F. Foster Richard P. Wilson, Esq.
- 3. Box 4263 Assistant Attorney General '
nrivor, Oregon 97702 - State of South Carolina P.O. Box 11549 I pirm:n Columbia, South Carolina 29211 l mic Safety and Licensing !
i nrd Panel
- Robert Guild, Esq.
1.
3 Nuclear Regulatory . Attorney-at-Law Comniccion P.O. Box 12097 Chington, D.C. 20555 Charleston, South Carolina 29412 l
(hand-delivered to Palmetto) i h
e
Chairman
- Palmetto Alliance Atomic Safety and Licensing 2135 1/2 Devine Street Appeal Board Columbia, South Carolina 29205 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Josse L. Riley Scott Stucky 854 Henley Place Docketing and Service Section Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Commission Karen E. Long, Esq. Washington, D.C. 20555 Assistant Attorney General N.C. Department of Justice Don R. Willard Post Office Box 629 Mecklenburg County Raleigh, North Carolina 27602 Department of Environmental Health John Clewett, Esq. 1200 Blythe Boulevard 236 Tenth Street, S.E. Charlotte, North Carolina 28203 Washington, D.C. 20003 Bradley Jones, Esq.
Regional Counsel, Region II U.S. Nuclear Regulatory Commission Washington, D.C. 20555 x=/
. Michael McGar J' n- .
III y
- Indicates Hand Delivery I
I t J