ML20091P924
| ML20091P924 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/11/1984 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| References | |
| NUDOCS 8406130224 | |
| Download: ML20091P924 (20) | |
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e i pELATED CORRESPONDENCE 00LKETfJune 11, 1984 l U3NRC UNITED STATES OF AMERICJB4 #113 p.11 :13 NUCLEAR REGULATORY COMMISSION CFI'2
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Before the Atomic Safety and Licensing or ec. .e B6ard i In the Matter of )
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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. 50-441
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, (Perry Nuclear Power Plant, )
i Units 1 and 2) )
e APPLICANTS' ANSWERS TO OHIO CITIZENS FOR
{ RESPONSIBLE ENERGY TWELFTH SET OF INTERROGATORIES TO APPLICANTS RELATING TO ISSUE NO. 16 Applicants'for their answers to Ohio Citizens for Responsi -
. ble Energy ("OCRE") Twelfth Set of-Interrogatories to' Applicants, dated May 14, 1984 (served May 15, 1984), state las follows:
1 All documents supplied to OCRE for inspection will.be pro-duced at Perry Nuclear Power Plant- ("PNPP") . Arrangements to ex-I amine the documents at PNPP can be made by contacting Mr. Bradley
, S. Ferrell of The' Cleveland. Electric Illuminating Company-("CEI")
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( at (216) 259-3737, extension 5520. Applicants will provide
- copies of any of the produced documents orLportions thereof which OCRE requests at-Applicants' cost 7f duplication. ~ Arrangements' for obtaining copies can be made with'Mr. Ferrell.
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' 8406130224 840611 PDR ADOCK 05000440 s e PM >
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On May 21, 1984, Applicants' counsel, Michael A. Swiger, conferred by telephone with OCRE representative Susan L. Hiatt j regarding clarification of Interrogatories #12-4, #12-5 and
- 12-7. Ms. Hiatt clarified that these Interrogatories should be read to exclude commercial considerations involved in the bidding
-process for the PNPP standby diesel generators.
RESPONSES 12-1. Produce a copy of the contract with TDI for supplying-the PNPP standby DGs. (OCRE is willing to accept a copy with monetary amounts deleted.)
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Response
l A copy of the contract with Transamerica Delaval, Inc.
("Delaval" or "TDI") to supply standby diesel generators'for PNPP, with commercial information deleted, is available for exam-ination at PNPP.
. 12-2. Identify all documents Applicants intend to offer as
, exhibits or use in cross-examination during this proceeding per-
- taining to Issue #16.
Response
Applicants have not yet determined which documents they will offer as exhibits =or use in cross-examination on Issue No. 16.
12-3. . List each and every failure, defect, deficiency, nonconformance, or problem occurring in'TDI diesel' engines; for each occurrence, state the type of application of the diesel en-
. gine (e.g., nuclear or'other stationary power source.or marine I
propulsion unit);.name' of the plant,' ship or other facility using
- the diesel engine; the rated. capacity of the engine (or genera-i -tor) the type of' diesel, engine (e.g., straight-8 or V-16) and all other~ relevant design information; the number of hours of 4
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operation when the problem occurred; whether the problem occurred l
during type qualification testing, preservice testing, inservice 1
-testing, or actual operation; the cause(s) of the problem; and ;
! all other facts, details, and circumstances concerning the prob- I lem. Identify all relevant documentation of the problem.
Response
Applicants do not have a comprehensive list containing the requested information. Considerable information concerning the operating and maintenance histories of Delaval diesel generators, in nuclear and other applications, has already been provided to OCRE through NRC Information Notices and Board Notifications and through previous discovery requests to Applicants. Additional information is contain?d in the Emergency Diesel Generator Compo-i nent Tracking System, Perry Nuclear Power Plant, Units No. 1 and 2, which is available for examination at PNPP.
12-4. Identify each and every reason why the bid of Colt Industries for manufacturing the PNPP. standby diesel generators was rejected. Specifically: (a) Identify every specification requirement which was not met by Colt, and explain why each such spec requirement could not have been conformed to the Colt bid.
(b) Identify whether the rejection of Colt's bid was .n any way based on Colt QA, reputation, reliability, or engine performance or operational experience; for each such attribute relied upon, thoroughly explain why it made Colt unacceptable and provide doc-umentation of Colt's unacceptable performance.
Response
(a) The specification requirements which both the base and alternate bids of Colt Industries (" Colt") failed to meet, and the reasons why the requirements could not be conformed to the bids, are discussed in PY-GAI/CEI-3235 (August 14, 1975). This document was produced for OCRE pursuant to a previous discovery b - _
request. See Applicants' Answers to Ohio Citizens for Responsi-ble Energy Tenth Set of Interrogatories to Applicants Relating to Issue No. 16, dated February 8, 1984 (" Answers to OCRE Tenth Set"), response to Interrogatory #10-9.
(b) The rejection of the Colt bids was not based on QA, reputation, reliability, engine performance or operational histo-
-ry.
12-5. Explain what " alternate bids" were received (see Applicants' answer to OCRE Interrogatory 10-10(a)) for the manu-facture of the PNPP standby DGs and explain why they were re-jected; expecially identify any reasons for rejection based on quality or reliability / experience concerns.
Response
Only Delaval and Colt submitted alternate bids. Colt's alternate bid was rejected because Colt took numerous exceptions to specification requirements which could not be conformed to the bid. See response to Interrogatory #12-4(a), supra. Delaval's alternate bid was accepted.as the basis for awarding the. contract to Delaval.
12-6. Identify each and every reason concerning QA, reputa-tion, performance, or operational experience of Cooper Industries relied upon to justify rejection of Cooper's bid. Identify any-documentation of such attributes concerning Cooper Industries.
Response
The rejection of Cooper Industries' bid was not based on QA, reputation, performance or operational experience. Documentation of such attributes is found in PY-GAI/CEI-3235 (August 14, 1975),
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which was produced for.OCRE pursuant to a previous discovery re-quest.. See response to Interrogatory #12-4(a), supra.
12-7. Produce the letter of inquiry and all bids received for the manufacture of PNPP standby DGs.
Response
The letters of inquiry are available for examination at PNPP. The bids received, with commercial information deleted,-
also are available for examination at PNPP.
12-8. Produce all corrective action requests issued by Applicants against TDI.
Response
All Corrective Action Requests issued by Applicants to Delaval are available for examination at PNPP.
12-9. (a)- Produce all stop work orders issued by Appli-cants against TDI.
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(b) For each stop work order imposed, state when and why it was imposed, when.it was rescinded, what TDI activities were af-facted, and what corrective actions were achieved.
- Response
a (a) All Stop Work Orders issued by Applicants to Delaval are available for examination at PNPP.
(b) _ The information requested is contained in the documen-tation package for each Stop_ Work Order. The documentation pack-ages are.available for examination at PNPP.
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12-10. Did Applicants ever place a resident inspector at TDI's facilities pursuant to SP-706 Sec. 1.05.3? If so, identify any person (s) so stationed, giving each person's full name, title, employer, and address. Produce any documented findings of any such person.
Response
A resident inspector was not assigned to Delaval's facility in Oakland, California pursuant to the specification.
12-11. Refer to the 12-21-83 letter from Murray Edelman, CEI to James Keppler, NRC R. III re starting air check valve mod-ifications, in which it is stated that TDI could not perform the modifications at their facility in accordance with ASME require-ments.
(a) Explain why TDI could not meet ASME requirements.
(b) Is TDI certified by ASME? If so, explain what areas the ASME certification covers and how such certification is awarded.
Response
(a) Delaval did possess certification by the American Soci-ety of Mechanical Engineers ("ASME") which would have allowed it to perform the modifications to the starting air check valves discussed in the above-referenced letter. However, the check valves were manufactured by a Delaval subvendor. In addition, ASME requirements included post-modification testing for which the subvendor, but not Delaval, had the necessary equipment. It was thus determined that the subvendor should perform the modifi-cations. ,
(b) DelavaliscertifiedbykSME, and currently possesses
- the following ASME certifications at its Oakland facility
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(1) ASME "N". Certificate;-- covers fabrication of.
Class =3 vessels, pumps, valves and storage tanks, and material supplying of ferrous bolting, cast-- -
ings, structural. shapes,-seamless tubular products and welding material; (2) ASME "NA" Certificate -- covers shop assembly of Class 3 components, appurtenances, piping subassemblies and component supports; (3) ASME."NPT" Certificate -- covers fabrication of.
Class 3 piping subassemblies and. component sup-ports.
Certification is granted by ASME in accordance with the ASME Boiler and Pressure Vessel Code, 5 III, NCA-8000. 'The ASME Code, 5 III, NCA-8000 is available for examination at PNPP.
12-12. Describe in detail the DR/QR program for the PNPP DGs; specifically, list each component which will receive a de-sign review; detail all inspections to be~ performed'on the DGs; identify.all-testing to be. performed; list all referenced reports-or sources of information. relied'upon to identify components, set acceptance criteria, or otherwise define the scope of the1DR/QR for PNPP, and provide a schedule for the completion of'the DR/QR for PNPP including scheduled times and' locations for conducting all inspections or tests on the DGs.
Responses-
- A list of the PNPP standby diesel-generator: components:which~
will undergofa design review under the Design Review / Quality--
. Revalidation Program'("DR/QR Program") is available)for examina--
tion'at PNPP. Identification of components was L based?on the TDI-
~ Parts Manual, vendor manuals,- Delaval and vendorL drawings, .
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Gilbert Associates, Inc. (" Gilbert") drawit.gs, the conformed specification, and site experience data. Inspection and testing plans for PNPP, including identification of inspections and tests to be performed, identification of acceptance criteria, and scheduling of times and locations, still are being developed. A schedule for completion of the DR/QR Program for PNPP has not yet been determined.
12-13. (a) Do Applicants intend to derate the TDI DGs at PNPP?
(b) Is derating the DGs an option in the DR/QR program? If uo, explain what factors or findings would influence or favor a decision to derate the DGs.
(c) If the answer to either (a) or (b) above is affirma-tive, explain in detail how the derating of the PNPP DGs would be accomplished.
Response
(a) It is not Applicants' present intention to derate the PNPP standby diesel generators.
(b) Derating is not an option in the DR/QR Program.
(c) Not applicable.
12-14. (a) Explain the statement at p. 3 of the Minutes of-Diesel Generator Users Group Steering Committee Meeting, Oakland, I CA, 11/29/83, i.e.: "No decisions should be made by the User's Group that could affect diesel generator manufacturer competition in the future."
(b) Does this statement mean that the User's Group will never find or proclaim any DG to be unreliable or of poor quality even if this is true?
(c) Explain why the User's Group chose to-take this posi-tion.
Response
(a) The statement to which the Interrogatory refers re-flected a then-existing concern among steering committee members that an Owner's Group-formed to review only one vendor could un-fairly effect future competition among diesel engine suppliers.
It was subsequently determined that this was not a concern; and the Owner's Group charter was written to limit its scope to Delaval engines.
(b) No. See answer to (a), above.
4 (c) See answer to (a), above.
12-15. Does the TDI' Owners Group have any studies planned or implemented concerning vibration in TDI engines? If so, pro-duce any plans or completed studies; discuss thoroughly any such plans or findings.
Response
The Owners Group will address engine vibration as part of the DR/QR Program. Detailed plans have not yet been developed.
12-16. Are components supplied by subvendors (e.g., the-generators) ever in the custody of TDI or are'they shipped di-rectly from the subvendor to PNPP? Identify all' components in TDI's custody, and indicate whether TDI performed any tests or inspections on the items.
Response
Components supplied by subvendors which_were required for assembly and factory test'ing of the PNPP standby' diesel genera-tors were shipped to Delaval. Applicants do not have a list of these components. Yes, Delaval inspected and tested components supplied by subvendors.
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12-17. Produce Agreement P-1152-S.
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Response
This document is the contract between Applicants and Delaval for-the purchase of the standby diesel generators. See response to Interrogatory #1, supra.
12-18. Explain the levels of expediting referred to in the-August 10, 1978 Expediting Report; i.e. does Class 4 represent a higher level of expediting than Class 6? Explain why expedition of TDI's work was sought.
Response
Levels of expediting refer to levels of monitoring vendors for compliance with-established schedules for supplying equipment to PNPP. All major equipment for PNPP that is purchased by con-tract is " expedited," Hor monitored. Class 6 is a higher level of expediting than Class 4.
12-19. Produce GAI memorandum PY-GAI/CEI-14003.
Response
Gilbert memorandum PY-GAI/CEI-14003 is available for exami-nation at PNPP.
12-20. Referring to the August 4,-198? letter from R. M.
Bonner, CEI, to P.B. Gudikunst,. Gilbert Associates, answer the following (a) . Describe in detail the " SWAT Team" referred to; explain its purpose and list all members'of the SWAT Team, give each member's full name, title, employer, and address.
(b) Describe in detail the outstanding problems referred to.'
(c)
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Identify the consultant designated to assist in manning at Delaval, and thoroughly explain,the consultant'.s' function.
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- . (d) ' Describe ~in detail any reports, findings, conclusions, d comments, or' recommendations . of the SWAT Team and the cor.sultant.
l- Response:
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j (a) The " SWAT Team" referred to in Mr. Bonner's letter is formally designated the Diesel Generator Task Force (" Task 4- ;
i Force"). The Task Force is a team of PNPP personnel designated to coordinate the solution of construction' problems' associated
- with the Delaval standby diesel generators.. The names, titles, employers and business addresses of team members are listed in j; Attachment A.
i (b) The " outstanding problems" referred to in the letter ,
l were Deviation Analysis Reports ("DARs") and Nonconformance Re-ports ("NRs") relating to the standby diesel generators which had not yet been closed out. These DARs and NRs were. produced for.
4- ,
! OCRE pursuant to a previous discovery request. See Answers.to i
i OCRE Tenth Set, response to Interrogatory #10-18.
l (c) A consultant was not designated to assist in manning at Delaval. "
j (d) The purpose of the Task Force'is not to issue reports, J
l findings, conclusions, comments or recommendations. See answer i
4 to (a), above.
1 j 12-21.- Is the task force mentioned in DAR 139 the-same'as i
the SWAT Team referred to above?' Iffnot,cidentify.all members of~ a' e the. task force giving.each person's name, title, employer,.and
- address; explain-the purpose of the task' force,,and describe any findings,' comments,. conclusions, and-recommendations of the task l
force.
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Response: t The Task Force referenced in DAR 139 is the same as the
" SWAT Team" referenced in Interrogatory #12-20, above.
12-22. On July 14, 1978 GAI issued a certificate of inspec-tion with waiver for the shipment of the first diesel engine; at-tached to the COI is a list of 6 exceptions. (Similar COIs with waiver and with similar exceptions were issued for the other 3 engines as well.) For each exception, demonstrate that resolu-tion has been achieved, giving the date achieved, the disposition of the item, and a reference to appropriate documentation of its resolution.
Response
The requested information is provided below. The following exceptions were listed on the Certificate of Inspection for one or more of the standby diesel generators.
Resolution- . Documentation Item Date Disposition Referende r-
- 1. Seismic reports
- a. Engine / 7/11/83 Approved PNPP Seisaic Generator and Qualification Skid. Components Report #94Q-300
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- b. Diesel' Control 1/9/84 Approved '##94Q-587, 590 System
- c. Generation 4/18/83 Approved ##94Q-26d,261, Control and 567, 693 Power Cabinets
- d. Excitor 4/4/84 ' Approved ##94Q-567,.693, Regulator 694 Chassis i
- 2. "Use-as-is". dis- 10/22/79 . Approved PY-GAI/CEI-15781:
position for weld- .(June 8, 1984) ing defects
- 3. IEEE 323 test reports
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, Reso? :' tion Documentation Item', s Date Disposition Reference
- a. Generator 6/27/83 Approved #94Q-297 r,
- b. Diesel Bugine 6/13/83 Approved #94Q-587 Control
- c. Siemens-Allis 6/3/83 Approved #94Q-556 Motors
- 4. Dohumentation N/A Approved Documentation Packages Packages (pages
, are stamped)
- 5. Deficient paint 7/31/78 Approved PY-GAI/CEI-15782 condition, (June 8, 1984)
- 6. Delava'S QA 7/17/78 Approved PY-CEI/VEN-160 QA program to 7/19/78 (July 24, 1978) 12-23. Demonstrate that the crankshaft deficiencies identi-fled in the Documentation Packages for Engines 2816/75053 and 2817/75054 (dents, scratches, machining errors and-nonmetallic inclusions) have been properly corrected.
Response
Documentation of corrective actions taken is included in the documentation packages for these engines. The documentation packages Eere produced for OCRE pursuant to a previous discovery request. See Answers to OCRE. Tenth Set, response tc Interroga-tory #10-9.
, t,12-24. Describe in detail the attempts Applicants have made to tdetermine the cause of.the excessive scuffing of LB #6 cylin-der' Liner and-the-large compre:3 ion differences observed in.the shop testcof the.first engine, alsa describe any findings and
)- corrective actions ma'de.
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a Responsc:
I It is not known what caused the excessive scuffing of the #6 cylinder liner or the compression differential observed during factory testing of the Unit 1,' Division 1 engine. The cylinder
, liner was subsequently replaced, and the #6 piston was inspected i before being placed back into the liner. On retesting of the en-gine under.the same conditions with the new-liner, no excessive scuffing of the liner or large conpression differential was ob-served. Subsequent factory testing of the engine has not re-vealed any compression problems. Compression checking will also be performed on the engine during preoperational testing.
12-25. . Describe in detail _any inspections Applicants con-i-
ducted on the fourth engine after-the piston ~ assembly / cylinder liner failure during the shop test to ensure that no other'compo-
- nents were damaged by the failure; describe any findings.of any.
such. inspections. Also describe all attempts Applicants madeito determine the root cause of the failure,'and any corrective ac-
! tions taken to' avoid recurrence.
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Response
The information requested is contained in PY-GAI/CEI-1380-QA (June 7, 1978), which was produced for OCRE pursuant to a previ-ous discovery request. See Answers to OCRE Tenth Set, response to Interrogatory #10-30.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: m V1 ~
12 4 JA . ILBERG, P.C. f MI E A. SWIGER G Counse f Applicants 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Dated: June 11, 1984 L
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_, _: J
, ATTACHMENT A DIESEL GENERATOR TASK FORCE
- Name Title Employer E. C. Christiansen Engineer The Cleveland Electric Illuminating Company ("CEI")
i-E. M. Root Senior Design CEI Engineer L. K. Routzan Junior Engineer CEI D. Jacobson Project Raymond Kaiser Engineer Scheduler (" Kaiser")
A. P. Pusateri Associate Kaiser Engineer L. A. Kilpeck Senior Construction CEI Specialist D. E. Stephens Test Engineer Gilbert Associates,-Inc.
T. J. Gaydos Construction CEI Analyst J. E. Barron Senior Buyer CEI W. E. Coleman Senior Engineer CEI G. K. Luciano Project Kaiser Scheduler D. G. Phillips Junior Operations CEI Engineer H. L.-Hrenda Associate CEI Engineer J. E. Magoon ' Associate CEI Engineer l
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u The business address of all members of the Task Force is i
! 10 Center Road, Perry, Ohio 44081 I
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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, 011I0 Edward C. Christiansen, being duly sworn according to law, deposes that he is Engineer, Nuclear Construction Department, of The Cleveland Electric Illuminating Company, and that the facts set forth in the answers to Ohio Citizens for Responsible Energy Interrogatories 12-1_through.12-7, 12-11 through 12-15, and 12-17 through 12-25 in the foregoing " Applicants Answers to Ohio Citizens for Responsible Energy Twelfth Set of Interrogatories to Applicants Relating to Issue No. 16," dated June 11, 1984, are true and correct to the best'of his knowledge, information, and belief.
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Sworn to and s scribed before me this _ day of Gws . ' /9TcY .
. strz ]' )/. b0s CAROLINE M. WILDE '
- Notary Public. State of Ohio My Commiss:on Expires April 17,1985 (Recorded in Lake County) i I
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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, OHIO Thomas G. Swansiger being duly sworn according to law, deposes that he is Supervisor, Procurement Quality Unit, Nuclear Quality Assurance Department, of The Cleveland Electric Illuminating Company, and that the facts set forth in the answers to Ohio Citizens for Responsible Energy Interrogatories 12-8 through 12-12, 12-16, and 12-22 in the foregoing " Applicants Answers to Ohio Citizens for Responsible Energy Twelfth Set of Interrogatories to Applicants Relating to Issue No. 16," dated June 11, 1984, are true and correct to the best of his knowledge,.information, and belief.
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Sworn to and subscribed before me this~ ffM - day of
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CAROUNE M. W!tDE -
Notary PubEc. State of Ohio , .
My Commission Expires April 17,1985 4
- (Recorded in Lake County)
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U:iNHC UNITED STATES OF AMERICA '84 JW 13 A11 :13 NUCLEAR REGULATORY COMMISSIONg gc,. g,,
00CXEimu & SLPvt Before the Atomic Safety and Licensing BodrdNCH In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing
" Applicants' Answers to Ohio Citizens for Responsible Energy Twelfth Set of Interrogatories to Applicants Relating to Issue No. 16" were served by deposit in the United States Mail, First Class, postage prepaid, this ll.th day of June, 1984, to all those on the attached Service List.
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- Michael A. Swiger 0W "
Dated: June 11, 1984
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l UNITED STATES OF AMERICA NUCLEAR. REGULATORY COMMISSION ,
_efore the Atomic Safety and Licensing Board B
i In the Matter of )
) .
l THE CLEVELAND ELECTRIC ) Docket Nos. 50-440
) 50-441 ILLUMINATING COMPANY
) .
(Perry Nuclear Power ' Plant, )
Units 1 and 2) .
) I SERVICE LIST Atomic Safety and Licensing !
Pater B. Bloc 51, Chairman Atomic Safety and Licensing Board Appeal Board Panel l 4
U.~S. Nuclear Regulatory Constission U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 Washington, D.C. 20555 )
Dr. Jerry R._Kline - Docketing and Service Section Atomic Safety and Licensing Board Office of the Sec;etary i
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Colleen P. Woodhead, Esquire
' Mr.'Glenn O. Bright Atomic Safety.and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Chairman i
Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appeal Board U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 Dr. W. Reed Johnson Terry Lodge, Esquire Atomic Safety and Licensing 618 N. Michigan Street, Suite 105. -
Toledo, Ohio 43624 Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Essone, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 center Street Appeal Board Painesville, Ohio 44077 l J
U.S. Nuclear Regulatory Commission John G. Cardinal, Esquire l
!- Washington, D.C. 20555
' Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Board Panel . Jefferson, Ohio 44047 U.S. Nuclear-Regulatory Commission Washington,- D.C. 20555 ,
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