ML20087M474
| ML20087M474 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/25/1984 |
| From: | Guild R CAROLINA ENVIRONMENTAL STUDY GROUP, GUILD, R., PALMETTO ALLIANCE |
| To: | |
| References | |
| NUDOCS 8403290379 | |
| Download: ML20087M474 (9) | |
Text
_________
ret ATED CCRT;spoNDENCE.
291 9utto u 3.*lRu UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'g4 giR29 go:49 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD p; ti y : ;,
C"CLe,i m a'Ty.',
In the Matter of
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Docket Nos. 50-413 Duke Power Company, et al.
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50-414
)
(Catawba Nuclear Station,
)
March 25, 1984 Units 1 and 2)
)
)
PALMETTO ALLIANCE AND CAROLINA ENVIRONMENTAL STUDY GROUP RESPONSES TO APPLICANTS' INTERROGATORIES AND REQUEST TO PRODUCE DOCUMENTS ON DIESEL GENERATOR CONTENTION Intervenors Palmetto Alliance and CESG hereby respond to Applicants' Interrocatories and Recuest to Produce Documents on Diesel Generator Contention.
This response is made on the following basis:
As reflected in the Licensing Board February 23, 1984 Memorandun and Order (Referring Certain Diesel Generator Issues To The Appeal Board) Intervenors Palmetto and CESG advanced certain contentions with respect to the unreliability of the Transamerica Delaval Emergency Diesel Generators at Catawba on the record of the licensing hearing December 5, 1983.
The Board announced its decision to admit only a portion of this contention in its decision announced February 17, 1984.
Tr.
12,541-12,551.
The contention as admitted by the Licensing Board reads as follows:
8403290379 840325 PDR ADOCK 05000413 J
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Applicants have not demonstrated a reasonable assurance that the TDI emergency diesel generators at the Catawba Nuclear Station can perform their safety function in service because of:
(1) inadeguate design of the crankshafts The Board excluded the two additional aspects of Intervenors' diesel generator contention but provided for a referral of these aspects to the Appeal Board.
The excluded aspects of the con-tention were:
(2) deficiencies in cuality assurance at TDI; (3) operating performance history of TDI generators at other nuclear facilities.
February 23, 1984 Order at p. 4.
Intervenors have supported referral of these issues to the Appeal Board and have sought reversal of the Licensing Board's exclusion decision and remand of revised site-specific claims regarding the diesel generators for litigation in this proceeding.
These matters remain pending before the Appeal Board.
The basis for Palmetto and CESG's December 5, 1983, diesel generator contention, which is the subject of Applicants' Inter-rogatories and Request for Production of Documents is reflected in the Board's February 23, 1984 Memorandum and Order at p.
1-5.
As of December 5, 1983, Palmetto and CESG had available to them the NRC Staff's Board Notifications83-160 and 83-160A of October 21, 1983 and November 17, 1983, respectively.
The original Board Notification concluded that:
The identification of QA problems at TDI, taken together with the number of operational problems and the Shoreham-crankshaft failure, has reduced the Staff's level of confidence in the reliability of all~TDI diesel. generators.
The Staff will require, on a case-by-case basis, a demon-stration-these concerns are not applicable to specific diesel generators because of subsequent inspections or testing performed specifically to address the above matters.
In the November 17, 1983 transmittal, the NRC Staff trans-mitted a report by Failure Analysis Associates with respect to the emergency diesel generator crankshaft at Shoreham.
The Staff observed, "in its report the consultants concluded that the original design of the crankshaft was definitely inadequate and, therefore, it failed as a result of high cycle tortional fatigue."
It was on the basis of these two Board Notifications and the failure report attached thereto that Intervenors claimed the crankshaft design aspect of the contention which has been admitted for litigation.
As the Board provided in its ruling admitting that aspect of Intervenors' diesel generator contention, Palmetto and CESG have served their interrogatories and requests for production of documents on Applicants and the NRC Staff on or before March 19, 1984.
These discovery reauests remain outstanding.
Palmetto and CESG have received only very limited information bearing on the admitted contention to this date.
We have been recipients of generally-circulated materials served pursuant to the Board Notification process upon all parties to proceedings involving facilities with the TDI diesel generators.
Such doc-umentary materials are believed well known to Applicants and the j
NRC Staff since they are-also indicated as recipients of such
(
materials.
In addition, Palmetto and CESG have received from i
Applicants a copy of their February 22, 1984-submittal in response 4
I to questions by the NRC Staff.
Further, by transmittal of March 11, 1984, Palmetto and CESG received from Applicants a February 20, 1984 submittal by Mississippi Power and Light Company with i
respect to the DSRV-16 model TDI diesel generator at its Grand Gulf facility.
This diesel is ostensibly similar to the diesels at the Catawba facility and is, we understand, relied upon by Applicants for qualification of the reliability of the Catawba machines.
It is on the basis of the above background and information available to Palmetto and CESG that we respond to the discovery filed by Applicants.
We note that Applicants' interrogatories, some 60 in number, are highly technical in character and call for the expression of expert opinion beyond that presently avail-able to Intervenors.
It is, indeed, ironic that Applicants who Intervenors believe to have failed in their responsibilities to assure an adequate design of their emergency diesel generator seek to place the burden of responding to highly technical quest-ions regardino crankshaft design onto these Intervenors.
As stated above, we rely for our concerns about the adequacy of the design of the Catawba diesel generator crankshaft on the objective evidence of failure at Shoreham and the expert analysis reflected in the Failure Analysis Associates' inclusion that deficient design by TDI was the root cause of the Shoreham fail--
ure.
We are only left to express our-concern that such design inadequacy may exist in the Catawba diesel generators likewise.
i REQUESTS FOR DOCUMENTS Palmetto Alliance and CESG have identified above the exclusive class documents pertinent to this contention which are available to them.
To reiterate briefly, Palmetto and CESG have been the receipient of generally-circulated doc-uments served upon parties to proceedings involving facilities with TDI diesel generators by the NRC Staff pursuant to the Board Notification process.
We believe Applicants to be fam-iliar with these materials as recipients themselves.
- Further, Palmetto and CESG are in receipt and possession of documents regarding the TDI diesel generators which have been served upon them by Applicants themselves, including the 2/22/84 submittal to the NRC Staff and the 2/20/84 Mississippi Power and Light submittal regarding the Grand Gulf DSRV-16 diesel generators.
Such documents are the only documents except for notes of coun-sel and other trial preparation work products which are per-tinent to this contention and in Intervenors' possession.
Palmetto and CESG will make available for inspection and copying any such material, not priviledged, to Applicants upon reasonable prior notice.
INTERROGATORIES A.
General Interrogatories 1.
These interrogatories are being answered by counsel for Palmetto Alliance upon consultation with Jesse L. Riley, the authorized representative of Carolina Environmental Study Group.
2.
No such person has been identified at this time. ~
i 1
3.,
4.,
- 5. and 6.
As previously stated, this contention is based upon the transmittal from the NRC Staff in the above identified Board Notif.ications and subsequent documents.
With respect to the crankshaft design issue, such documents include the transmitted Failure Analysis Associates study of the Catawba crankshaft which, apparently, embodies the results of a number of calculations, tests, and experiments which are reflected therin.
B.
Specific Interrocatories Palmetto Alliance and Carolina Environmental Study Group are unable to provide answers to the following numbered specific interrogatories due to their lack of sufficient knowledge of the highly technical matters reflected therein.
We do not believe that the answers to such interrogatories are readily ascertainable by us, but have not yet received answers to our March 19, 1983 interrogatories and requests of Applicants and the NRC Staff on this contention.
Thus, we lack sufficient knowledge at present to answer the following numbered specific interrogatories. 1-5, 8, 9, 17-34, 40-58, and 60.
With respect to a number of other interrogatories contained in Applicants' discovery requests Palmetto and CESG are of the belief that answers to such questions might be within the exper-tise of Intervenors, but only as a result of extensive indepen-dent research and analysis.
Such research and analysis is not presently available to Intervenors although such-information may- - -
i be reflected in the yet unanswered interrogatories and reauests for production made of Applicants and the NRC Staff and now pend-ing.
At present, therefore, Intervenors lack sufficient know-ledge to respond to the following numbered specific interrogatories:
6, 10, 12-16, 35-39, and 59.
11.
Yes.
On the basis of review of the Staff's Board Notification 83-160A and the attached " Emergency Diesel Generator Crank-shaft Failure Investigation, Shoreham Nuclear Power Station" prepared by Failure Analysis Associates (October 31, 1983)
Palmetto and CESG agree that the Shoreham diesel generator crankshaft failures were caused by high-cycle tortional fatigue.
Respectfully Submitted, Y
N
- b. /
Robert Guild
/%
2135 Devine Street Columbia, South Carolina 29205 (803)254-8132 Attorney for Palmetto { Alliance.
Jesse-L.-Riley 854 Henley Place Charlotte, North Carolina 28207 (704)375-4342 Carolina Environmental Study.
Group March 25, 1984 --
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket Nos. 50-413 I
50-414 DUKE POWER COMPANY, et al.
)
(Catawba Nuclear Station, March 2 5,1984 Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of PALMETTO ALLIANCE AND CESG RESPONSES TO APPLICANTS' INTERROG ATORIES AND REQUEST TO PRODUCE t
DOCUMENTS ON DIESEL GENERATOR CONTENTION in the above captioned matter has been served upon the following by deposit in the United States mail this 2 5 th day of March,1984.
James L. Kelley, Chairman George E. Johnson, Esa.
Atomic Safety and Licensing Office of the Executive Board Panel Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 1
i Dr. Paul W. Purdom
- Albert V. Carr, Jr., Esq.
235 Columbia Drive Duke Power Company Decatur, Georgia 30030 P.O.
Box 33189 Charlotte,. North Carolina-28242 Dr. Richard F. Foster P.O. Box 4263 Sunriver, Oregon 97702 Richard P. Wilson, Esq.
Assistant Attorney General State of South Carolina Chairman P.O. Box 11549 Atomic Safety and Licensing Columbia, South Carolina 29211-Board Panel
- U.S. Nuclear Regulatory Commission Chairman Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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Jesse L. Riley 854 Henley Place Scott Stucky Charlotte, North Carolina Docketing and Service Section U.S. Nuclear Regulatory 28207 Commission Washington, D.C.
20555 Bradley Jones, Esc.
Regional Counsel, Don R. Willard U.
u1 r Regulatory Mecklenburg County Department of Environmental Health Cogmission Washington, D.C.
20555 1200 Blythe Boulevard Charlotte, North Carolina 28203 J. Michael McGarry, III, Esq.
1200 Seventeenth St., N.W.
Washington, D.C.
20036
[
nch'=rt Guild, Esq.
/
Designates those served by overnight mail or delivery service.
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