ML20093F443

Testimony of Gd Eley,Cj Smith,Gc Minor & DG Bridenbaugh Re General Motors Electro-Motive Div (EMD) Diesel Generators & 20 MW Gas Turbine.Prof Qualification Statements Encl.Related Correspondence

ML20093F443
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/16/1984
From:	Bridenbaugh D, Eley G, George Minor, Casey Smith SUFFOLK COUNTY, NY
To:
Shared Package
ML20093F417	List: ML20093F413 ML20093F443 ML20093F460 ML20093F471 ML20093F484 ML20093F501
References
OL-4, NUDOCS 8407190237
Download: ML20093F443 (97)

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1 UNITED STATES ~OF AMERICA A NUCfiEAR REGULATORY COMMISSION 4

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Bef5re th'e Atomic Safety and Licensing Board

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.LONG ISLAND. LIGHTING COMPANY' ) Docket No. 50-322-OL-4 Q- f t. ) (Low Power)

'(Shoreham

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TESTIMONY OF G. DENNIS ELEY, C. JOHN SMITH, GREGORY C.

MINOR \ AND D ALE G. BRIDENBAUGH ON BEHALF OF SUFFOLK COUNTY R}EGNRDING EMD DIESEL GENERATORS AND 20 MW GAS TURBINE Introduction and Qualifications Q. Please state your names and positions and describe your professional qualifications.

A. My name is G. Dennis Eley. My business address is 1301~ Metropolitan Avenue, Thorofare, New Jersey 08086. I am a

' Technical Manager with Ocean Fleets Consultancy Service, Ltd.

I have a combined First Class' Department of Trade and Industry Certificate of Competency (Steam and Diesel), and a Higher Na151onal Certificate in Mechanical Engineering. I also am'an Associate Member of the Institute of Marine Engineers, and a

, Member.of the-Institute of Port Engineers. 'Si,nce 1959 I have held various engineering and consulting positions with concerns engaged-in the design, manufacture and operation of ships and related machinery, including diesel engines and generators. In 8407190237 840716 i PDR ADOCK 05000322

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these' positions I have been responsible for the efficient operation of various diesel engines, boilers, air compressors and refrigeration systems. My qualifications are set forth more' fully in my resume which is Attachment 1 hereto.

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_My name is C. John Smith, and I am an Assistant Technical Manager with Ocean Fleets Consultancy Service, Ltd.

My-business address is 1301 Metropolitan Avenue, Thorofare, New Jersey 08086. I have worked as a Marine Engineer with Ocean Fleets forEthe past 22 years, after joining them as an Engineer Cadet in 1962. I hold a Department of Trade and Industry First Class-Certificate of Competency (Diesel). During my employment with Ocean Fleets I have had experience in the operation, main-tenance and repair of a wide variety of makes of diesels, including Allen, Burmeister & Wain, Deutz, Diahatsu, Doxford, General Motors, Mak, Mitsubishi, Paxman, Petters, Rustonk, Sulzer, and Volvo, in applications both as generators and prime movers ~ onboard ships. As part of my employment I have been F

required to attend two fire fighting and prevention courses Egiven by the fire departments of the cities of Liverpool and Leith, England. In recent years'I have been actively involved in_the design and implementation of fire and safety procedures onboard ships. I also hav,e attended-the building commis-sionings and delivery of four new ships, requiring the

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inspection of machinery and systems for correct operation and compliance with statutory regulations. My resume is Attachment 2 hereto.

My name is Gregory C. Minor. I am a founder of and currently am a Vice President of MHB Technical Associates. My business address is 1723 Hamilton Avenue, San Jose, California 95125. I-have 24 years of experience in the nuclear industry including design and testing of systems for use in nuclear power pl~ ants. For 16 years I was employed by General Electric

Company as a design engineer and manager of engineering design organizations. My responsibilities have included the design and qualification testing and preoperational testing of safety systems to meet safety criteria' applicable to nuclear power plants. 1I have also worked 8 years as a consultant with MHB Technical Associates. These consulting activities have includ-ed work on nuclear plant safety features and designc for gov-ernmental and private organizations as well as public interest groups. My education is in electrical engineering (with a ,

powe'r systems option) resulting in a B.S. degree from the Uni-

-versity of California at Berkeley and an M.S. degree from Stanford. :My qualifications are set forth more fully in my

' resume,which has been submitted with the Testimony of Dr.

Christian Meyer,'Dr. Jose Roesset, and Gregory C. Minor on Behalf'of Suffolk County.

p-l My name is Dale G.,Bridenbaugh. I am President of MHB Technical Associates, and I serve as a Principal Consultant in the performance of my firm's consulting activities. My business address is 1723 Hamilton Avenue, San Jose, California 95125. I am a Mechanical Engineer by education, having received a BSME in 1953. I am alsb a registered professional Nuclear Engineer in the State of California. I have more than 30 years experience in the engineering field, primarily in the areas of power plant analysis, construction, maintenance, and operations. A substantial portion of my experience was as a field engineer supervising the installation, operation, and maintenance of central station power plant equipment, including steam turbines, gas turbines, and emergency power generators.

Further details of my experience and training are contained in my resume-which is Attachment 3 hereto.1/

Purposes'and Conclusions Q. What'is the purpose of this. testimony?

A. The Long Island Lighting Company ("LILCO") has re-

- quested an exemption from the requirements of 10 CFR Part 50, If Unless otherwise indicated,.all answers in this testimony are sponsored by all witnesses.

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Appendix A, GDC 17. LILCO proposes that it be allowed to operate the Shoreham Nuclear Power Station ("Shoreham"), at up to five percent of rated power, without a fully qualified emer-gency, onsite AC power source, that has been designed, procured, manufactured, installed, and tested in compliance with all applicable NRC licensing regulations, and that has been adjudged to meet these requirements (" qualified onsite emergency AC power system").

Instead, LILCO proposes to operate Shoreham using a configuration which enhances LILCO's offsite AC power system, consisting'of a set'of four mobile diesel generators manufactured by the Electro-Motive Division of General Motors Corporation (the "EMDs") and a 20 MW Pratt and Whitney gas tur-bine.

This testimony addresses the question whether

- operating Shoreham at up to five percent of rated ~ power relying on LILCO's proposed, alternate sources of emergency AC power would be as safe as operation at up to five percent power relying on a qualified onsite emergency AC power system. In particular, this testimony addresses the reliability of the EMDs and gas turbine starting and running, and their overall availability, compared with a fully qualified onsite emergency

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i AC power system. For purposes of this evaluation this testimony compares the EMDs and 20 MW gas turbine to LILCO's originally proposed onsite AC power system (the three diesels procured from Transamerica Delaval, Inc. ("TDI"), as it was en-visioned by the FSAR.

Q.- Describe briefly the onsite emergency AC power sources described in the Shoreham FSAR.

A. The orginally proposed onsite AC power sources

. consist.of three TDI diesel-generator sets ("EDG's") rated at 3500 KW'each. Each of these units is housed in a separate reinforced concrete compartment which is_ designed to withstand the Shoreham safe shutdown earthquake. Each unit is designed to> start automatically and to supply power sequentially to nec-essary engineered safeguards systems that are needed to assure safe shutdown and maintenance of reactor cooling and contain-

-ment.. integrity in the event of a loss of coolant accident coincident with a loss of offsite power (a " LOOP-L'OCA"). All appropriate design criteria, such as protection from fire and

-missiles, separation and single-failure, and other criteria necessary to assure on-site power reliability are committed to be followed in the design, procurement, installation, and operation of_.these units. This includes a commitment to a

Quality Assurance ' program in compliance with the requirements of 10 CFR 50, Appendix B.

O. What is your conclusion?.

A. Our conclusion is that low power operation of the

Shoreham plant at up to five percent power relying on LILCO's proposed alternate AC power system would not be as safe as such

. operation with onsite emergency AC power sources that were fully qualified and satisfied all applicable regulatory re-quirements.

Low power operation in reliance on the proposed, alternate AC power. system would not be as safe as such operation in reliance on a fully qualified set of onsite AC power sources, because the EMDs are not as reliable as the lat-ter. First, unlike fully qualified generators, the EMDs have a number of common features that make them vulnerable to single failures. Second, the EMDs have no fire detection or fixed fire suppression systems, and therefore fire in one of the EMDs would be much more likely to incapacitate it and make operation of the other EMDs difficult if not impossible, than a fire in a qualified diesel generator. And, because the starter battery is~ inadequately ventilated.and isolated from potential ignition sources, the threat'of explosion or fire in EMD 402, where the

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battery is. housed, is greater than would be true-of a qualified ,

-diesel generatdr.

Third, the alarms and monitors of the EMDs are not

. indicated in.the control room, and all but one of them are Jannunciated only when the diesel shuts down. Consequently, unlike the case.with qualified diesels, the EMD alarms are un-likely to lead to human intervention to remedy a developing problem:before-it causes the unit to stop or otherwise become

-inoperable. . Even at the-local' control panel the EMD alarms are not specific enough to-facilitate timely diagnosis and repair i'

of; failures with the machines.

. Fourth, LILCO's proposed procedure for testing the

-EMDs.does not provide adequate assurance that'the EMDs will function-as expected in an emergency.1 The proposed. procedure

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Ldoes not test 1the automatic elements.of-the.EMDs, and the pro-cedure, ' as designed ,. is not. likely to1 reveal. significant, developing mechanical problems. 'Fifth,'unlike a fully quali-

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.fied AC1 power source, the processes for. starting the EMDs and

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connecting-them to the safety 11oads in the plant are not fully

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, ^ _nutomatic.- Consequently, the EMDs are more vulnerable to fail-urei d ue to' human error, and are less reliable than a'~ completely automatic, qualified generator. set. Sixth, the' maintenance and f- m.

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repair histories of the EMDs indicate that the EMDs have

. experienced both component failures and the need for overhaul much-too frequently. Mechanical failures of the sorts experi-enced by.these machines cast doubt on their reliability.

g (Minor and Bridenbaugh) Low power operation in reliance on the proposed, alternate AC power system also would be less safe than such operation would be in reliance on a fully qualified set of onsite AC power sources, becausa the gas turbine is not as reliable as the latter. First, LILCL has not developed an effective surveillance testing program that provides adequate

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verification of the reliability of the gas turbine. Second, the alarm and control systems of the gan turbine are insuffi-cient.- Third, the gas turbine and its fuel system'are suscep-tible to seismic and missile damage, and the gas turbine is vulnerable to single failures. Finally, the gas turbine is es-sentially a new installation due to modifications in its control and starting systems. None of these vulnerabilities or inadequacies is a characteristic of the originally proposed onsite AC power system, and consequently the gas turbine is less reliable than that system.

(Minor) In. addition, the proposed alternate emergency onsite AC power system,is less reliable than the originally

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proposed AC power system, because it is more complex and therefore~more susceptible to equipment failure and human error..

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The EMD Diesel Generators Q. 'What are the common features shared by the EMDS that

-render them susceptible to-single failures?

A. . ( All Witne'sses) The EMDs share (1) a single electri-

- cal output circuit from the EMD control cubicle /2 to Emergency Bus;11.in the plant;-(2) a. single starter system consisting of one. battery array, one battery charger, and one starter control

' mechanism;fand (3) a: single fuel supply system.

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all the, breakers connecting the individual EMD generators to their~ common' bus are located-in the EMD control cubicle.

.Q. Describe the single' electrical output line from the EMD' control-cubicle to Emergency Bus 11.

A.. The electrical. output of each EMD is carried by buried.

;g cable.t'o;the EMD control cubicle, where it is connected through Lan-electrical breaker to a. single three phase bus.3/ 1The

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/. .The EMD." control cubicle"-is a small, enclosed structure located inext to EMD '401.-. The control cubicle houses the electrical.and mechanical control equipment for the EMDs.

-1/ 1An' electrical bus typically is a copper or aluminum bar or plate-housed'in an1 electrical cabinet or~ enclosure. Be-(Footnote cont'd next page)

_ . output of all four EMDs is then carried by two three-conductor cables in'a single-raceway, which-runs approximately 100 yards

.'from :the control cubicle to the switchgear room, and a quarter

'of'the length of.which is covered by sand and stucco.

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Q. How.does this1 single output line compare with LILCO's originally proposed onsite AC power source?-

A. The power output of the ,three qualified diesel genera-to'rs intended :to be provided at Shoreham are completely sepa-r .

rate and independent. Not only are the diesel generators themselves--housed in separate compartments designed to with-stand all-design basis loads and phenomena, but each unit also

,is provided with all necessary auxiliaries and controls for in-dependent operation. The power generated by each of the units is distributed by electrical systems provided with " physical and electrical separation of bus sections, switchgear, interconnections, feeders, load centers, motor control centers, 3 1

and other system components." (FSAR 8.3.1.1.1).

i (Footnote cont'd from previous page)

- cause it is enclosed, it normally is not insulated. It is used to facilitate the interconnection of power supplies Land associated branch circuits.

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Q.. How does the single output circuit affect the reliability of the EMDs when compared with a fully qualified emergency.onsite AC power source?

A. If the single output circuit became inoperable due, for example, to any electrical mal' function or mechanical fail-ure in the control cubicle, it would be impossible to transmit power from any of the EMDs to the plant. By contrast, because the power produced by each of the three qualified diesels is transmitted independently, the failure of one output line would affect only one generator. The other two would remain capable cf generating and' transmitting power. Consequently, the EMDs are less reliable, because a single failure in the output line would make all four EMDs unable to supply emergency AC power.

Q. Describe the common starting system for the EMDs.

A.- The common starting system for the EMDs is comprised

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of=a number of components. Included is a battery array housed in EMD 402. This array consists of a number of individual lead acid batteries connected in series, which provide a total available voltage of 125v. The battery array is connected to a stepping switch located'in the EMD control cubicle. The

-stepping switch is necessary, because the battery array is ca-pable of starting only one EMD at a time. When a start signal r ,

is given,-the stepping-switch directs the battery power to one machine at a time, moving to the next machine when the first machine starts or fails to start after 15 seconds. Also in-cluded in the starting system is a battery charger located in EMD 402. It is connected to the battery array, and is intended to maintain'it in' a fully charged state.  !

.Q . Describe the starter system for a set of qualified

'onsite AC power sources.

A. The starting systems described in'the FSAR that were to be provided for the fully qualified EDGs were substantially more' reliable than the system provided for the EMDs. The FSAR' states:

Each diesel generator set has a separate air starting system designed to be capable of starting the diesel engine without

, external power and also to meet the single fai'.ure. criterion. The air storage tanks and piping between tanks and the air. start distributors are designed to ASME Boiler and Pressure Vessel Code Section III, Class

3. All other portions of this system are

' designed to manufacturer's standards and Seismic Category I requirements."

(FSAR 9.5.6.1) Further: .

Each [ qualified] diesel generator is pro-vided with two independent, redundant starting systems. Each independent starting system includes the following:

1. One ac motor-driven air compressor with intake filter L

2. One air compressor after cooler

3. One refrigerant air drier with moisture trap

4. Two check valves

5. Two. air storage tanks with relief valves and drain valves

6. One manual shutoff valve

7. -One strainer

8. Instrumentation and control systems

9. Air starter distributor system

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Each' independent redundant air starting system is of sufficient volume to be capa-

.- ble of cranking the engine for a minimum of five starts,-without recharging the tanks.

Each motor-driven air compressor has the capacity to recharge the air storage system.

-in_30 min to provide for a-minimum of five starts. Its' motor is furnished with auto-matic start and stop control on pressure signals from the air storage tanks.-

.(FSAR 9.5.6.2).

Q. How does the common starter system affect the reliability of the EMDs relative to a qualified set of onsite power sources?

A. ~The EMDs are less reliable than' qualified onsite gen-erators, because, unlike the latter, the failure of the single

- starter system could make it impossible to start any.of the

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L E SMDs. The.failur'e of the battery array and/or charger could render the-starting system inoperable. Similarly, if the starter control mechanism in the EMD control cubicle failed, although electricity would be available to power the EMD starter. motors, that. electricity would not be transmitted to them, and none of the EMDs would be started. Therefore, the

setz of three qualified onsite generators described in the FSAR would be more reliable than the EMDs. As noted above, each TDI diesel generator is provided with-two independent, redundant starting-systems. (FSAR 59.5.6.2.) Thus, the failure of one starting system would not incapacitate even one qualified gen-

erator, and f ailure of two systems could only prevent the starting of one generator. The other generators still would be

-able to supply emergency power to the plant. By contrast, the failure of one starter component could prevent the entire EMD set from starting and from transmitting any power at all to the plant.

Q. Describe the EMD fuel supply system.

A. The EMD fuel supply system also consists of several components. They include individual 130 gallon " day" tanks in each individual unit, which are joined together by an equalizing pipe. Fuel from all four day tanks flows through s

.thel equalizing pipe in a manner which keeps the fuel in all

'four day tanks at the same level. Fuel is supplied to the day tanks by two transfer pumps located in EMD 402. Normally, only one of these two pumps operates; the second pump will run if the fuel level in the day tanks drops to an abnormally low level. These pumps draw the fuel through a single above ground pipe.line.1/ This pipe runs next to the EMDs at the foot of a steep embankment. It passes under a temporary ramp constructed to-allow vehicles to drive up the embankment, and ends at a fueling station.-- At that point, the pipeline is connected to a

. flexible hose which in turn is connected to a 9,000 gallon tank truck. Fuel from the truck is drawn by the pumps through the

. hose'and supply pipe line, into the day tank in EMD 402. From there it flows to the other day tanks-through the equalizing pipe. The EMD fuel supply system is illustrated in Attachments 4, 5 and 6.

Q. Describe the fuel supply system for a set of qualified onsite diesel generators.

4 /- We understand that LILCO has now committed to put this

-pipe ~ underground. When data are available regarding the new pipe design, it may be necessary to amend this testi-mony.

A. Each-of the three TDI diesel generators described in the FSAR has its.own fuel system, which is physically isolated from.the fuel systems for the other two generators. Each system consists of a' completely buried tank and two foe 1 supply pumps' housed in their own concrete block house. All components are designed- to withstand the credible seismic events that may occur. Each system also has its own fuel supply line, which is buried. .Thus the tanks, pumps and supply lines are protected from common fires and missile events. In addition, each gener-

'ator also has-its own " day" tank, which is isolated from the other_ generators' day tanks.

Q. How does the design of the EMD fuel supply system affect'the reliability of the EMDs relative to a set of quali-fled onsite AC power: sources?

A. The fuel _ system.for the EMDs presents another single failure vulnerability that is absent from the qualified emer-

.gency AC power source described in the FSAR, and as a result,

.the EMDs are less reliable than qualified AC power sources. In the case of qualified generators, if a failure rendered a fuel 1

. supply system inoperable, because each qualified generator has an independent fuel supply system, only one of the three gener-ators would be affected; the other two generators could

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-continue to produce power. By contrast, it the EMD fuel supply system failed, all four EMDs would be affected, because they all. receive ~their fuel;through that single system.

~For. example, because all the fuel for all the EMDs flows through_the pumps and day tank in EMD 402, an interruption of

. the fuel' supply in that unit would interrupt the flow of fuel to all four EMDs. Thus, if a fire occurred in EMD 402, or if ithe pumps or float switches in EMD 402 failed, fuel would not

- be transferr'ed f rom the single supply pipe to the day tanks of any of the'EMDs. Similarly, because all the day tanks are

interconnected.by the equalizing line, any single failure, such as a rupture due to a seismic event, could adversely affect all

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four EMDs.

The single failure vulnerability created by the'EMD fuel: supply: system is heightened by two features that are par-ticularly susceptible to the kind of failure that could affect all~the EMDs.-

First,-fuel for the EMDs is transferred from~the tank truck into the supply line through a hose running from the

truck. This hose'apparently just lies.on the ground as it runs ffr'om the? tank truck to-the connection with-the supply line.

M  :(See Attachment 7. ) The area in which'the tank truck and. hose 18'-

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s are located is an area with significant construction activity,5/ and consequently it is quite possible that the hose could be damaged by construction activicies or equipment. Be-

-cause the fuel for all four EMDs flows through this one piece of_ equipment, damage to it could terminate the flow of fuel from the tank truck to all four EMDs.

Second, the single supply line that carries fuel from the hose to EMD 402 is susceptible to failure due to both ground motion and missile impact. As other witnesses for suffolk County have testified, a seismic event with ground ac-

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celeration of 0.2g's could cause the pipeline to rupture. (See Testimony of Dr. Christian Meyer, Dr. Jose Roesset and Gregory C. Minor _on Behalf of Suffolk County.) The supply line is also susceptible to damage from missile impact. For example, at the point at which the pipe issues from under the south side of the ramp-(See Attachment 4) there is no protection from the possi-bility of a vehicle,'such as an articulated truck, striking and rupturing the_ pipe. Again because fuel for all four EMDs-flows through this pipeline, damage to it would interrupt the flow of fuel from the tank truck to all the EMDs.

5/ Completion of the Colt diesel addition program (through preoperational testing) la not expected until mid-1985, well after LILCO's proposed low power test program would likely be completed.

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0. _ How is the reliability of the EMDs affected by the location of the breakers for all four EMDs in the EMD control

-cubicle?

A. The reliability of the EMDs is reduced, because a single event, such~as an electrical fire in the control cu-

.bicle,'or missile damage,~could disable all four breakers and make itLimpossible to transmit emergency power from the EMDs to Emergency Bus 11.

Q .- What fire protect' ion systems were included in the onsite AC power system originally proposed for Shoreham?

A. The onsite emergency generator system originally pro-posed for Shoreham contained both fixed fire detection and fixed fire extinguishing systems. These fire protection systems, as described in the FSAR (Section 9.5), contain permanent.and_ automated detectors and fire suppression devices in each'EDG compartment. These systems are designed to auto-

.matically. activate CO2 fire suppression systems which flood the compartments with CO2 gas. The' fire protection systems also

. provide immediate alarms in :the main control . room to assure t'.. a t followup operator action is initiated. Because each of the three TDI-EDGs is in its own separate compartment, these.

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-systems operate _ independently to enhance the reliability of each unit.

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Q. -What fire protection systems exist for the EMDr,?

u A. The EMDs contain no fire detection equipment and no

fixed, remotely operated fire extinguishing system. The only fire < extinguishing equipment associated with the EMDs is a small number.of hand-held fire extinguishers stored inside the EMD units and two fire hydrants located-in their vicinity.

Q. How does this lack of fixed fire detection and.sup-pression systems affect the reliability of the EMDs relative to a set of fully qualified onsite AC power sources?

A. It makes the EMDs less reliable than the qualified sources. First, it is unlikely that a fire in one of the EMDs would-be discovered until it-was too late to extinguish it

' expid itiously. Because-the EMDs are not fitted with a fire de-tection system, the first indication of a fire would be smoke or= flames escaping from the housing of an EMD. Even then de-tection would only occur when someone happened to see the smoke or flames.

-By the time a fire in an EMD is sufficiently well established to cause smoke or flames to issue from the housing, it?may be so well established that it will be impossible to enter the EMD housing and apply an extinguishing medium to the

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seat of the fire. Without the ability to direct hoses and extinguishers at the seat of the fire, it is very unlikely that the fire could be extinguished before the EMD was rendered in-operable. Consequently, personnel responding to the fire would have to be content with containing it.

In addition, the vulnerability of the EMDs is in-creased by the fact that it is unlikely the other three EMDs could be kept running if one EMD were burning. Fire fighters responding to such a fire would almost certainly want to iso-late sources of fuel from the fire. This would mean stopping the flow of fuel from the tank truck as well as isolating the day tank of the burning unit. Consequently, the other three EMDs would have only the fuel that was in their day tanks when the burning unit was isolated. Also, operating EMDs draw large amounts of air. Therefore running them while a neighboring unit is burning creates the risk of drawing flames into the non-burning machine through the air intakes. Similarly, be-cause the fire fighters almost cer'tainly would spray large amounts of water on the non-burning EMDs to cool them, there is -

a risk that water could be drawn into the running EMD through its air intakes. Finally, a fire in EMDs 401 or 402 could result in water being sprayed on the nearby EMD control cu-bicle. To eliminate the risk of electrical injury to the fire fighters, the flow of electricity through the switchgear in the control cubicle probably would have to be stopped, thereby

. preventing the operation of any of the EMDs.

This situation makes the EMDs less reliable than

. qualified, onsite generators, because they are more vulnerable to fires. -By way of example, with LILCO's originally proposed diesel generators, any fire would be detected quickly; indeed the precursers.to the fire, such as hot gases, might even be detected-before the fire actually began. And once a fire was detected, the fixed mitigation system could quickly attempt to extinguish it. A fire in an EMD almost certainly would inca-pacitate the EMD, whereas one of the originally proposed diesel generators would have a much better chance of surviving a fire; and while a fire in one qualified diesel would not affect the others, a fire in one EMD would make it very dif ficult to con-

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tinue to run the others.

Q. As.-he EMD arrangement.more vulnerable to fire hazards in any other ways?

A. Yes. The absence of-fire detection and fixed fire suppression equipment is a serious shortcoming in any diesel configuration, because operating diesel engines always present a potential for fire. But this shortcoming is especially

serious with respect to the EMDs, because they are more vulnerable to. common fire damage than the diesel configuration

. originally proposed by LILCO. Unlike a set of qualified diesel generators, the EMDs are not separated by approved, fire barri-er valls. The EMDs are simply sitting in a row, with each unit (See Attachment

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approximately 8 to 12 feet from the next one.

4.) Consequently, there is a greater potential that a fire in one EMD could spread to the other EMDs and prevent the entire set from supplying emergency power to the plant.

Moreover, the EMD starting battery array poses a

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threat of explosion and fire. When the EMDs are started, the starter battery is partially depleted, and it must be .

replenished by the battery charger. While they are being charged, batteries generate both oxygen and hydrogen gases. The hydrogen gas is a potential source of explosion. Safe operating practice dictates that batteries should be housed in a compartment with no potential sources of ignition, and which is ventilated to outside air either naturally or mechanically in a manner which prevents the accumulation of explosive gases.

.Neither of these practices is followed with the EMDs.

The starter. battery array for all four EMDs is stored beneath the floor of the engine compartment of EMD 402. Instead of

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ventilation that carries potentially explosive gases to the outside air _, gases generated by_ this starter- battery are vented into the' enclosed engine' compartment of EMD 402. There those gases are exposed to electrical devices, such as lights, light

$ witches and relays, all of which-could create sparks and ig-

^-nite an: explosion andcpossibly a fire. (See Attachments 8 and 9).

An' explosion or fire could incapacitate EMD 402. But

'it also'couldJdisable the common starting. system for all four

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EMDs by destroying the battery. It also co'uld incapacitate the fuel supply system for all four EMDs, which runs through EMD

'402. Consequently, the threat of explosion or fire resulting

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from the' improper ventilation of the starting battery array.is a potential. single failure that could prevent the operation of the' entire EMD set.

There is no comparable threat of explosion associated with the originally -proposed diesel generators, because their starting systems utilize no' batteries and therefore there is no source of hydrogen. (FSAR 9.5.6.2) 4 l

i Q. What are-LILCO's proposals for testing the EMDs?

A. LILCO proposes to conduct bi-weekly surveillance p

testing of*the EMDs. The details of this plan are described in Temporary: Procedure TP 24.307.04. Rev. O, June 7, 1984. By this procedure, LILOO will manually start the EMDs one at a

- time to be:sure-that three of the four mobile diesels "can be manually started and operated at rated speed." This process is deficient in that it does not provide for regular testing of the. automatic starting, synchronizing, and load sharing mecha-

- nisms as these devices would be required to operate during the LOOP-LOCA scenario. Consequently, LILCO's proposed testing

~ wouldinot identify potential problems with key automatic elements-of'the EMD configuration, and as a result that testing

. does-not provide an accurate indication of the reliability of

- the EMD system. :The need for regular testing of these systems is demonstrated by the fact that-during an electrical function J ' test performed on July 2, 1984, one EMD failed to synchronize; and during. attempts to restart-this machine,.two of the other EMDs tripped off.

In addition, there are specific deficiencies in the proposed test procedure aside from the failure to test the entire Ei!D system. (see Attachment 10, which is an appendix to w-

J , L@- i-

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Procedure

, 3 _, .

TP'24.307.04 that sets fo'th the steps to be followed

^

b -- k in the' manual starting (and loading of the EMDs). First, the

._ f .r .

,, ' procedure ilobs not prfvide' for;a visual inspection of each EMD L

.(. . c..- ,

prio [to starting.' th'ef.e ng ine . Such an inspection is good

~

_.~ a:r. . :"l f s.. ,

operating-practice. Ittpermits the operators to ensure that

,s

-the required amountfof vitalffluids is present, and that equip-

' ment- f ailures,or hdun errors heve not lef t .the engine mechani-

~

Starting ihe'en'g'ine without a v'isual inspection

~

--cally unsound.

increases the risN that the machin'e will be damaged and ren-f bered inoperable. 2 cv

d. } f ,

a Second,/although the General Motors manual for the

., 2 <

,.x -f

. .EMDs states: that prelubrication of the' EMD engine is a "neces-

&sary"and.important practice for any engine which has been u;g * >. -

+. . ,. .

% xinoperative fo'r more:thanL48 hours"-(See Operating Manual, MU-20E Power Plants for Peaking, Reserve, and Base Load 7

E 3-jj OperatioY( the "EMD Operating Manual"), at 9-17), the LILCO ,

It5st procedure does not require the "necessary and important"

~t prelub'ricstion. ,

. f.

g N 7

a:

m- - Third, the LILCO test" procedure does not indicate how

? h. ,

long . an Et4D. should be run once <lt has been started and

~

p 'co'nnectdd!th electrical loads. Consequently, it is possible

^

- that theEl4Ds will not be run long enough at their normal e,

f -

J

- 27 -

x

-1 l'i :p '

.l d .

't b n t-)~

operating temperature to allow temperatures to stabilize in individual components. Stopping an engine before this occurs reduces component life and operating reliability.

Fourth, the LILCO test procedure does not call for a visual inspection of the machines while they are running. Such an inspection is important, because many developing mechanical problems can only be detected while the engine is running. If no one inspects the machine while it is operating, such problems could go undetected. As a result, the operators would not have the opportunity to repair the problem before it became serious enough to make the machine inoperable.

Finally, the LILCO test procedure does not call for a visual inspection after completion of the test. Thus, LILCO passes up another. opportunity to discover developing problems with the machines. Moreover, a post-test visual inspection

' serves to verify that the soak back lube oil pump for the turbocharger is operating properly. Failing to verify that the soak back-pump is functioning increases the risk of damage to the turbocharger.

2 How do the deficiencies you have identified in LILCO's test procedure relate to the reliability of the EMDs?

.1 , .s-l A)w;-

a

's a

t

?

A. Eaci~offthese'deficiences results in a missed oppor-1tunity to discover 1 developing problems with the units, in-

. creased' risk of damage to components, or reduced operating life of components. Consequently, all of these deficiencies reduce the reliability of the EMDs.

-2.. How does the alarm monitoring present in the EMD con-

- figuration' af fect its reliability when compared with qualified diesel generators? .

A. ' Inadequacies in the EMDS' alarm system make it less likely.that: they will operate reliably than would a set of

-qualified diesel' generators. When qualified onsite diesels are operating, personnel in the control room-are informed of devia- .

tion .of .the diesel systems f rom design -parameters '( e .g. , cool-f ing,? fuel, lubrication) by alarm systems that are displayed in the control room. Early detection of an abnormal condition giv'es the controliroom personnel the-ability to take corrective action before the-condition deteriorates to the point at which the diesel (s) automatically stops.- Thus, the operating reliability of-the diesels is enhanced by adequate alarms.

.,The EMDs.do have alarm systems, but all the alarm

~

signals except

one (" Abnormal Fuel Tank Level") are given only

~ when ~ problem becomes serious enough to initiate an engine F'

29 -

~

l A.

.I e

% 4 g

shutdown. That is, all but one of the alar go off only when it is too late for human intervention to correct an abnormal condition prior to shutdown. In addition, the EMD alarm system

. is not.sufficiently: precise to facilitate the prompt diagnostic and repair act' ions that would be needed to restore to service a failed EMD. Indeed, four of the alarm lights on the EMD annun-ciator panel cover 17 separate shutdown causes. For example, if the " Engine Stop" light and the " Generator Breaker" light come on simultaneously, the problem could be low engine

-lubricating oil pressure, low engine cooling water level, excessive crankcase pressure, engine overspeed, or an open breaker. Consequently, when . f aced with those two al' arms, the operators would have-t'o check a long list of potential problems in order quickly to repair the EMD.

e By contrast, the description of the alarm system

- contained in the Shoreham FSAR sets forth the comprehensive in-strumentation provided for operation and' monitoring of a typi-cal qualified'onsite AC power system.

Surveillance instrumentation is provided to monitor

.the status of the diesel generator. Provisions for surveillance are an essential requirement in the Ldesign, manufacture, installation, testing,

. operation, and maintenance of the diesel generators.

Such surveillance not only provides continuous monitoring of the-status of the emergency generators so as to indicate their readiness to perform their intended function, but'also serves to facilitate

'.__.;.,m-J-

I i

2 1

~

2. testing and maintenance of the. equipment. Conditions f -- whien can' adversely-affect performance of the emer-U ~ gency diesel generators .are annunciated locally and

in the main control. room. - The following list shows T the important. functions that.are annunciated:

J q

{

4 y!*-

n' 5'.. e e:

u 9

i i!

h '..

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r L.~ .

$ 9 esS t-P ye' 1@Wm W -W --e w W w- +-Wt-Wg -w-- --N- y yy y-cyyfw-- -g-g-W9-e ' wig-M

Alarm Control Function Local _ Room

1. Low Pressure Lube Oil x x

2. High Temp 6cature Lube Oil x

3. Low Pressure Turbo Oil x

4. High & Low Temperature Jacket Water x

5. Low Pressure Jacket Water x

6. Low Level Jacket Water x

7. Low Level Fuel Day Tank x

8. Low Level Lube Oil x

9. Low Pressure Starting Air x

10. Aux. Pump Switches Off x

11. Low Pressure Lube Oil Shutdown x

12. High Temperature Lube Oil Shutdown x 13 .- Low Pressure Turbo Oil Shutdown x

14. High Temperature Hacket Water Shutdown x

15. - High Pressure Crankcase Shutdown x

16. Overspeed Snutdown x x

17. Low Pressure Fuel Oil x

-18. High Level Fuel Day Tank x

19. Low Flow Service Water x -

20. Fail to Start x

21. Unit Unavailable x

22. Diesel System Degraded x

23. Diesel' System Inoperative ,

x

24. Diesel Engine Trouble x

25. Emergency Bus Supply or Feeder Breaker Auto Trip x

26. Generator Neutral Ground Overcurrent x

27. Low Level Fuel Storage Tank x

28. Generator Field Manual Shutdown x

29. Generator PT Blown Fuse x

30. Generator Voltage Regulator Power Failure x

31. Main Board Control Disabled .x x

32. Generator Heater Loss of Control x

33. F.O. Suction Strainer High Differential Pressure x

34. Jacket Water Conductivity High x

35. Motor Driven Fuel Pump Running x

36. Field Flash Inoperative x

37. Fuel Oil Transfer Pump Locked Out x

38. Fuel Oil Booster' Pump Strainer High Differential Pressure x r

/

m -

NOTE: fAlarm No. 24 includes Local Alarm Nos. 2 through

'10 , 17, 18 ', 19, 20, 27, 28 and 34 Alarm No. 23 includes Local Alarm No. 21 and 36. Alarm No. 22

-includes Local Alarm No. 32.

(FSAR 8.3.1.1.5)

Moreover,' the EMD alarm indications are only given on an T

annunciator panel in each EMD unit. This means that during

. operation the EMD alarms cannot be read from the control room, but~instead can.only be read if operating personnel actually monitor the individual annuciator panels in each EMD unit.

LILCO's procedures do not provide for operators to be in the EMD. units during their operation. ~The only indication in the

' control room of the status of the EMDs is an indication of

whether any voltage is being supplied by the EMDs. There is no indication in the control room of how many EMD units are

?-

operating, how they are sharing the load, or if one or more are in' difficulty and/or about to shut down. Consequently, it is possible, for example, for only one EMD to be operating, with-out. control room personnel knowing that the other three have In contrast to the situation with the originally

~

shut down.

' iproposed diesel generators, in such circumstances the operators of'the EMDs would not know how close they were to losing all

-their EMD-supplied power. Thus, the operators would be unable to attnmpt to head off developing operating problems before l

1 I - 1

f f those problems forced the EMDS to cease operation.

1 Consequently, the reliability of the EMDs is less than that of a set of qualified diesels that can be monitored in the control

. room.

-Q.- .Are-the EMDs started and-loaded in the same manner as qualified, onsite AC. power sources?

A. No. The: normal design of safety-related onsite emer-gency'AC: generators is to have power.available within 10 seconds of a-loss of offsite power. (FSAR 8.3.1.1.8) All the starting and loading. functions are performed automatically without operator' assistance. ' LILCO's originally proposed

?

onsite AC power systems were designed to meet this standard.

By contrast,. starting andiloading of the EMDs is a smultiple step-process. The starting sequence is automatic, but

' .at total-of at:least 18: manual operations, performed by opera--

tors under the. potential stress of an. emergency situation, are requiredLto connect-the necessary electrical-loads for the

engineered safeguard systems to the EMDs. (See procedure TP

85;84042.3,-Rev. 1, pages'6, 7. ) - A, start: signal is given si - g Lmultaneously to all-the EMDs by the EMD autostart system upon loss of .voltsge. on the EMD bus.. However, because-only one

, ' cranking. battery is provided for ~ all four units, electricity is 34 -

t r

E F - e w --e - , - .w w,y--,.-e< .,y +.,-c..m---

r.--- -w,,r-:-w v - - ---*r'~w-rswg-t w e w = = m wm w- - r + w +wr v -w

9 >

l 1

provided to..each unit's starter motors serially. The starter

- -control mechanism in!the EMD control cubicle supplies starting lpowerJto each EMD, one at a time, for cranking. After the

~

first unit 1has started, or has cranked for a timed period, the I control L mechanism. switches. power to the-next EMD. After a 90 I

second-warmup period at idle speed, each engine goes to full speed as soon as engine oil-pressure is satisfactory. The first engine to reach full-speed has its speed adjusted to give the correct frequency and is'then connected to the EMD bus. As the'other machines come up to speed, they are sychronized with the first machine and then connected to'the EMD bus. When all the running EMDs are synchronized and connected to the EMD bus, they can be manually connected to Emergency Bus 11.

The EMD Operating Manual estimates that for deadline

_ start it will take approximately 2 minutes for one unit to start, idle, accelerate and be ready to receive load. -However, loading is not done until the' last unit is synchronized with

~

-the other units and all units are' ready to be loaded. This means-that for four units it will take between 2 minutes 20 seconds and 2-minutes 50 seconds to have them synchronized and ready to accept load, in contrast to the 10 seconds required by-the FSAR.

l I

i

In addition, in contrast to the fully automated operation of qualified onsite AC power sources, operation of the-EMDs depends on the actions of human operators. Conse-quently, the risk of human error is greater with the EMDs, and this additional risk reduces their reliability. Before the

.breaket-from the EMD bus to Emergency Bus 11 can be closed, supplying power to the emergency loads, field operators must manually (1) remove three undervoltage program fuses in the service water pump cubicle; (2) open the gas turbine feeder breaker, the feedwater pump feeder breaker, and the 480V substation feeder breaker, in the normal switchgear room; and (3) go outside to the Normal Station Service Transformer

("NSST") and open three disconnect switches on the low side of

- the NSST. 'Those disconnect switches and the NSST are depicted in Attachment 11. LILCO's procedures call'for an operator to be' dispatched to perform these actions. (See Procedure TP 85.84042.3, Rev. 1, Step 8.5.1) In order for an operator to

~ leave the control room and complete those necessary tasks, he

~

must travel nine flights of stairs, pass through approximately 15 doors'(6 of which are locked, security doors, and require a credit card-like key to open), and he must pass one security

. station. The large number of stairways and doors involved in this process increases the chances that the operator will be unable to. complete his assigned tasks in a timely manner.

t-u

O' x

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s ,s f

' [

t

'In addition, step (3) above-requires the operator to ileave the building, climb overLthe EMD cable raceway, and'open

threet switches on.the NSST. In order'to 'open the switches, the 1

operator =hasito use an approximately twenty foot'long fiberglass' pole, with a' hook at.the'end. The. difficulty in-

>volvedjin performing this task increases the risk of delay.-

' Moreover, the difficulty of opening these switches under ad-verse;weathercorflighting conditions is significantly in-

- creased,Jespecially because.there is no emergency lighting in

the vicinity of t h .;337.

In Aliition, tna impact o f 'a a:n a n a r r o r potannict .in

.thn--ooeration of th( E1Dc is turther incr21329, oecause it'is rid 9: 333ryffar oo?ratorc m?nually to managa tn2 load of tna 2133 tr37'th? C 10 c o n +. c o l - c ub i c l e s . .

'(saita) LILC3 3:rsonnel Save ac knowl erig ed luring a

-rve"nt 3t'1onstration taat' manual control of tne'lo333 placej on ta r- ? !~)3 couli be nes?sstry to'?nsure tnat th7 engin?s ao not Ni a t Inv!n 104 annagh to be --letrimental to the machinu.

( ;11 .titnassas) Tht; nacesntry locil management in-cruase; tua risk. of naaan.artor, es.c?cially oecnase tn2 C-ID 23ntrhl cabielo contains caly one sat of currenc and poser

+attro; monitoring t'ns loai on aa:n C:10 is consequently a 37 -

.gs ps: .

W

-- .;;LT s ..._

v_ p & : n <

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C -33 p ,

m _

.320ias' tats nanaga. tant 2 n c r e ?. 3 ? 3 cn2 riu f; M& P u.m N r s u-p a c r o c e 3 3 '. .

' :A

g

of1 tu nnffltilur ?,7 taa.-r sli sbility of too MCs r 91 st tv a to ta a t

.n .- w,a. iv

.. iutons,. .o c .ie r: tourc~.: is Cecr233:.i.

4 y - ,

ih

{-g 7. - USht'inforn tion r21 sting to-tnc reliability of tae i

_ ?3i?sDit cantainei in t17 r1:oris'ot-::,:ir;maintenanc.e an.:

4

.c:mir.Nistorias?

Q,. ( F.l ay~f an i +aith) ria; maintenance records for tna e, .. .

- - o g3ffyr..

n,y p3rio:Lin throu;n 1933 sho. t.u t 2xclusiv.e of 4(

PS7 ,

'r2ptg .; int 1.ofLaarts.at scae.9.uled maintenance parlo5c tne tol-

<x <

' ' s  %:iin) 3 #aundntadv.vs S W to-b2 r2plac2:1:

, y,.

m j . 17x::y1indar neads- '

• J21S?ow r 13samblics ~( a: och2r asarabif consists

. :of ,co:nplot2,cyl inder ,. pictaa .and cy) inder-

, .m y m T h ?15 ):

+< a ...

. ;- turbochar pra

- '13 l s t.ic ta r s. no ta r,9 -

4

,r F y

^

_-m . -

2TnUfsfl. ira}ot this faamberiof major comnonenta over an :nver ige

'~

L.o fi a, ?M,? hours pe r Em1chini i s g rea ter "taan 'exp setc.i f or rel i-

~

LS E3'.ilDJ 1 a n l's )5/

1 n m d'u r t;i?rmor a , - [1 thou3'1 the E 4D J0oir atin3. Itanu11 scatsa s, ,

m . .

o t% t c o. noua r ini.7_f L.shoul:1 t akc .~ olaca at -12,0FJ acurs and; Power A- . . .

4

'% E f

a _

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y? 0 /L d31ient. 2vsnes f r<ra j tha T. tint:n nce ani r 20. air" historics

' ' ' J o f1 :q : -.C lD3 Are"20t>forth in Attachments 12 tirougn la.

$. /

n M ,

3/.. ' d 1 T " r ecod2r ing"' th? cylinder ' Accwanlies ( oiston, piston

~

' frol,:: .:/l iaie r 'an3 ' cyl in ~42r cui) , an5 tha foul-injectors u '

(Pootnot2 cont'u na<t pag:)

9: , 4

+

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• L

,I,:-- 6 ep _

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k' . .

p:l u'

w-t i

.;y3:2.r.s (LILCD'c igent far maintaining t1? E 133 ) sta:? in it; fii n t ,a in;-' ag ra nent xitti L I L ") tut repow7tinj snaula t v. ?

ol 1.: - mfter 1;,000 nura, t19 ninten anc^ r ?coris 343.: tnit

-:1 M 101 1,3 203 only ran 5,'130 nourn actor' requiring c ' 20,;2 r i ng . e. ins 402 7ni 101 nava only 5,30) oni 5,003 cours, res7? tiv7!y, sinc' tney .ier: Citted uita Utex Cngines.d/

lon2t%2123s, 'fter th?ir installation insoection 't Jaar.nsu,

'a>?r

.- iyst'-ns.543 concar7c about th? :ae:hanical coalitica of.

C P> s 4 '; 2 rn- '34 ' ni s t a t r' in its inst 11ation inap'etion r2:3rt tnat th2 "!-In.Ji n: components cre us23 and nyproacning au-ra,u.." a Cocian af the rel2vant pages of the ins t all.i ti o n i u;w.clon recort erv ut:4:ael to this testinony as Attucanent

1. , .

7

-(Footnot2 coot'd iro a previous page) t L

3r3 repli:23, an3 tie following parts are cuack23 ana innge:1 or a!juctoi as n22: led:

conn?; ting roi bearings piston coolin) tubes roc <?r armn, rock?r arm bunninga ani can Collowers 1.s9 7djusters exhiest valve timing 9

.nter pangs l

1/ A 'st?x Ca.)ia2 in 1 factory rebuilt eng in ? orougnt up to a3 Sr.i staalardn.

- 3:> -

312e riiitional, 372 ific incidents locument;3 in tn.

mtint'nincy i ls'.orl?3 of tN? U -103 .mico liva riaa to Jar conc era sboot tocir rcliauilit/ are Mcseribei b e l o .z .

3, t 12,5 3 2 '1our n (i.e., anly C,943 hours0.0109 days <br />0.262 hours <br />0.00156 weeks <br />3.588115e-4 months <br /> after n.. v i a ]

)2n fitt95 zitS -2 utex eng ine) , tne engine in E

4D 4 G L sa5 ruo3;eraa. ~Bigity-s? van hours later poser unitsl/ 4, 6, 10, ll, il 2n3 i? na3 to 'co changed again b2:ause of J3 mage to the

07) : 1.iers sti oistonr, that hed occurre3 in :ne snort time at' tar

a? reco.:' ring. Tfter a tuttnar 15 minutes of running, Poaar Unit No. 11 wa ag3in changa! be:Tuse of cylinier/olston nn 32. F'ar tnic number of componentn to b' chang?1 3a saon

' f : ? r o'r 'r'la ul ( w:1en they acul 3 b.' 2xp?cted to last sporoxi-mit 21 / l',0JJ J nours) indicatas tnat either tile maintenanes or raucoments wer9 of poor quality.

i Tne turbo narger on E:4D 40% failad at IJ,)32 ;1ours.

TT2 not nnl e x n a c t sri lite of a turbocharger is 32,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. A T9r? 71: Sours latnr the new turbocnar3?r f aile1 in such 3 f r3nion :nst pi:cos of the orok?n turoochargar ciarcoa tne

't r ' renal te ? , requiring rhnm to be cl.an.;e3 3190. Thos? two 2/- 4 anottar Unit" consinto at the cylinier hr?3 sasembly, cylinder liner, oiston 193cmbly, carrist ass 2mely, ennn,.'eting rol assambly, Oni all rolitoi Jaar.2ts and n nln.

e

=

lh =

=

m- -

failur23, i31013.5 .itn tae fact that u.1D turbo:ncrJ9rs asv2 ';a .

1 history or problans (c2? P.a t t a ra a n t at tna 5100tro-lotive raroo:12r;er ~Gi Au). 1932) inlicat that tais cc:nconent nas laa r?llability.

In light of the facts that tna E'40s nave required taa r791 e2 snt si parts du2 to failures as well as repowaring 7.uch mor* f r luently tnan one sauli axp?:t, it saens likely nnt ta 3re to 3Sne 33rious 'Jeficiancy 2itner in some of tie .nocninas or'in tha minn2r in wnich tney have baan maintsined. In aitn?r

? vent, the et M ni T.e:nnnical t-iilure seems higher than it

noull 3~. ihin incr ased rink in mrjo wors? by tne fact th;t LIL ']'s test procedura is not 23cquate to Jiscover davaloping Tiachanicsl prooloma. The 2nd result is anotnar factor thac re-Outts'tha caliiDility of tuo t:lDs.

M9 21 ~t.. 0 as turbina 0  :-las L1LCD ievelopai in effnetive surveillance tact gr rj r n far tn2 gas turbina to assure it sill be availab1? waen n?,1?i?

. (linor and 3risenbaugh) N2 have baan proviia1 witn only two 333 turbin? tact procedures, 39 24.307.07 (Dratt) and TP 1 ; . M 7.11, Rev 1, July 2, 1984.1S/ Gor review of tn233 tuo ll/ CP 21.3s7.)) 1100 naken re t er anca to an unli2ntit iv 2 "bi on'ily 13 M M 101

1 tast" aut 42 hav? b nn unacte to le-t ? r:ai n ; if id0h 3 tatt pr?:Clare ia i Jct JXiStJ, 3r wait its purpas? nay 09.

cro::iaran 12ain us to conclude talt tney are not an erf2ctiv?

sarvaillan ' crogrrn for tne naw s arvice assi3nu. to tne gss turvin.~.

Proc 2 dure IP 24.237.02 is 2atitlci " 'J i x cio n t a s a r -

i;i]l'in:a on 23 -b! 01s forbine Genarator :Jo. 2". The separant

'purpaca of thta procciure in to demonstrate.tn2 ability at tas unit to at?.rt *ni carry sor.2 safety ralated inni in the avaat of 1 Icas of off-site cover. Durin) tnis cost tne gas turoina

~is;relairei~to carry the loa 2 of only one or two op2rsting W1it panos tron th) 13 3 e nieg ancy bus. Thes? two pumpn have : tot:1 power rating af 199 3 LJ, 30 if bat 5 are r un simul t.ineoca.l y, this would 1999 the gas turbin? to approximately only lut of its rating. l'h ? o r e<:eiur e is silant as to how long tna 1o13 nhoul1 n carri31.

Proc?iuro GP 24.30T.07 in entitlei ":iontnly Olack 3 tart Tust of the 20 't.i Gas rarbina." It calls tor the gas turnino to b2 st a r tei , -l o r3 ai and oparatei tot at le sat ona hrir overy two we94s, and to be black start 23 montaly. ("ul ::s utart" la tn? t?rm use.1 to define a compon?nt v1ich hs; tha snility to st .rt sni oper.1te with no external ?oser oeing s'i ppl i"4 to it.) Tan spacific test inclui2d 33 in appanSix to t161 proemlure in ti,ntific1 as a "'lonth'ly Test" but Sescrib23 G

}lt ,

n T

"E

~

L' Jin?s u p.:23 t7.eJo?rlormsnca of a " I 3 M ? ' b iw e n.1 y 1023-tent."

f ,:It r i s , .ic;ord in.;1y, no t ci o :r anat - test e c .pi r e aen t is'oain3

'- I d L f;il19 3 ty.5- this pr oe'-ture , 4nd sa conclude ta3t.tne final ca-t 4 t i s n ive ;- no t y? t' aean - dev ?l'ap21. .

je ~ 05 you!concluie-taat: tae surveillance test pro 3 rut.

t: .p9r.-ta?'jas.tbrhino.is inef(?ctivo?

s; .s '.(;;inor 2n 1. deidenosugh)' Yes.

rne six month tastia3 M'th?'jassturbins at_only 5 to 10 09tc2nt of-ita rate.i cac :i-Lty f or ' a nan-q? tine.1 perioi of time ioes not suf ticiently t tx th' anit?to. verify-its rullability. The test is too ency. T P :-

on ! ranth J('or. perhaps ti-z?ekly) loatJtest is obviously not yet

.i >v 3 t oond .

. .i;t?st in such a preliminary stage of levelopment labs not :i w a Well'?aough-'definal 90313,-procedures, or &ccep-

~tsoce-crit,ri.1 to provida -330 luato verification ol ._the reli*bility of' the gas' turbina tot tne servica for.snien it n.19

-bhan ?roposei. *)ur~ position that tne proposed test.ts not saf-

~

ficisar'to;v?tify th? ability of :nis ontt to supply the na:3s-

~

sary.1'oaJs is soppartej oy the Nn: Staff's review of tnis issac tacartri in tao 3.,fety Evaluation Report ('wR&3-0420,

?9aapl?mant 3, - Apr il: 1984 ) . In this report, tne Staff expressei

' concern regar;ing tne possible imposition of non-safety lonas s on tne gns turbine th t:could result in a totsi o f l'i '4U on en e 13 r

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l dn't. T7? 5tarf nos r ecommen] en :aore tr a.iaant tuli 1013

--t sting eni mantaly testing to verify that th2 normal 6 '; N .m 2 1.15 W .l.ons ,till autom9ti:211y 31sconnect. ( ';U B C G-3 4 2 ) ,

Junplate,- 5, cagn s-2 and S-3). -

). 00 st tna 3noranam control room n n2 auequate contrais ani u aras f or . monitoring tu? co2 ration of the 2] 4;7 gaa tur-oin??

.\ . . *(v.inor nni Gri3anbau)n) 2n? only indication availabic 17 tqe 593renam control room from ani:n operation of tne gas Lt2thinc con be infarrel is the indi:ation of voltage on the 53XV.line 2n] a light flich in:licates sne tner the 20 '4,7 g as -

turoine br'ther is op?n or clos 93. Inus, as is tae case wita tn: C'10s , the coerttors in tne control roon cannot nonitor tne operation of t h .* 3as turbine in the m" ner made possible by tne comntenansive 11arn monitoring system associated aith the orig-inally propose'l onsi te AC power systam. Consequently, alth the g n tarbin9, the operators Jo not have tha same ability to in-terv ?ne ani rectify deveioping problems witn the unit's op? ration th, tney have alth resp 2ct to the originally pro-posti,onsit? a; pow?r syntom.

. 'loreover, under most coniitions, the gas turbina can only.b? n ? ? t i t ?.i at ene local control pinel at the gas turbine 41 -

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L l or by tn' LILCO syst em on7t:ito r i n ili a K 3v il l a , if the cnntral in 2 - u2 for r'not: contral. If en 'ontrols a r e; 37: for e l v? :, start o n? r .i t i o n , th?n tha unit is sucoss:.1 to start tuta-m-ti;311y it alltage is lost on tilu 59%V line. rhus, tner? is no . ny ' to st irt ti,- 20 tr; J us turnine manually f rom tne 559r me, control room, short at artiiicislly crasting a Inss or n o .12 r  :.'v on t by - i sol a t ing the 69 7,V lin2. Tha control root oo-erator can 7t directly start or initiata :: rustart attempt of th; j 20 tarbine as a precautionary or supplemental moscure.

Cons 2quently, too only way en3t the gas turbinh cwn a2rve tne

-n?: ): of 3hornh'n in 1 tinely manocr is if ita controla ar?

'l?ft in en? oropar auto start position, and it p?rforms cor r.actl y iur in] a lona of oftsit? power event. If it 11i121 t1 start properly, the only sly to 3 2termine the status at the ucain9 and att? mot 1 restart vauld c2 to dis 9stch an up.erstar to tic gic turbina, ani tnat would take too long.

2 13 the gsc turbina protected against phenonens such as sciatic events, external missiles and othat po t en ti .xl l / 112-utractive 7vantc?

4. (Minor ini 9 tid'nbaugn) The gas turoine is not l?qi7nei P3 69 able to withstini tne C5creham saf2 abatiown 93rts3J247, nor in ito taal supply tank. TSO turbino is not 45 -

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-:?qc16srij by. anythin g o taar tnan a w?atnerproof enclosure, uni ntioratore,c 'its opdration is vulneriole to missilac suen as ttios:.Jthat coul.libr generat?i by Calling aireraft.

13 thr g?3; turbine designc3 to satisfy the singla f.

0. 3 failurj criterion?-

A. '(:;inar 2nd-GriO9nbaugh)' 40, it is not. Sacadse tne

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L Jgao1tur51nt;;is a single unit, t..' failura of any on2 or .aany 5 ictiti;d-compshants could~ prevent or int 2rruot its operation.

'6f m rticalar importan:21iscits r21iince on a singla starting ayit s et .ni .i single fu21 sapcly line routed to it f ro.n t.ie f u e l p

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t an t -1.porlv. i.na t?ly ~4 0 ya rd s aw ay. r7is fuel lina cou13 b? sc-vor21 bylminailh?irapact, such ns falling transtaission towers or M 1 1' i n ? 3 , or authof-control motor-_ vehicles. ( g Attachm?nt:17.)

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2.- Doy71tha past- per formance of the ps turbina. proviit Ttsur snc2: thati i t Wil1 ??rform r 2113bly in the future?

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1~ ' A. .(ftinor'ini 9rijenb7ughi

- r19 , it do.2s isot. Although

t itis . unit nad .30V ?ral' tnousand- 53urs of operation .in the past, a %itz Jac .;noved to Ghoreham only in thO Spring of 1334.

g Di n:t hat Nith tnis mov.2, the control an3? starting e.luipment

!ni;2s;3cy to;orov Ha' black start capability aus added to thic s qnit. . Thus, .-it' 'Is . ?ssentially a new instalid ion wi th the

, .inui2rsnt"3tirtup "ougs" still to be norkel out.

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,reintive tovthe originally cropos?1 onsita AC power system?

.R . (linor :.ind ' Br iS anbaug n) Tna 20- 1.i g as- turbine is not ins.r liablea:n-:end originally propos?3 onsit? AC power systan.

-I t.' 5 9 7 3_ no t. ne a t tne single.Lail'ura critorion, it is not quali-fici!to aitnatani ,ny of tne necessary-design oasis pnenomen.,

' .7nilit---is' nat :ven _unier taa. control of the Shorona a control room._op ;1 tors._ Soreover, LILC3's. proposed test procedures ao not.aiequately .; assure the reliable operation of tne unit, ani

-its al rm iaoni toring . is' ina 32gu.1te. None-of tnese

- yuln?tanilities or.:in133quacien present in the 20 Md gas tur-Jbin,Leonfi 3uration are present in the .atiginally proposed

. canite.AC power system. As f r2sult, the gas turbine is not as r e 11 Abl o -- 7 s t*1 ? Istter.

Comol exity 'of. tae Pr onose:1 Altornate

'; C Power'3ystem

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. 'In ah t .nys =is tno proposed, alternate AC posar

' ~sy7te n L mor, complex tnan tne originally propos?d AC power systn?

A. ' ( *3 ino r ) - tne electrical' connections associate 1 sith tn? 11 tern;ta A0 power system proposed by LILCO ar? :no r e 4

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coani'u tnan tnosa nasocist25 wito taa or13 inallf prop 0ssi antit? 'C.oader sourc2.

. I'ne E1Ds ar: not conn?ct26 iire:tly to t12 cmorgency 1035 contars (Buses 131, 102 ani 10J). To rc3cn tn,a.= cnnt'rn, A0 pawar from any Zaa must pacs through 3 circuit brank2r3 ani 2 busas. Catput from tan 20 11 gas tur-

-bind m u r. t ' tis k ? :n 77en longer and less ?rt31n rout $ in criar to a rc -ta.2 saf 7ty lor.in connected to tne emergancy 4 ?V bus 73. P7a2r from the gas turbin? must pass tnrough 3 circuit

'o ' r 17. k 7 r s , 3 3sitc123 and 2 tr anstor.nars. 'y 3 contrast, ;C posar grouucv3 oy one of tne originally proposci onsita generators muze 77ss througa only 1 intarv:ning .l uv ic a , a single circait ornik7r, in'ord7r to r27ch saf aty loads conn?cteo to an .2 mar-g?ncy 4 KV bus.

J.  !!aw ices tqis increased complexity affect tne r2113bility of th? proposci alternat? AC posar system relativa to.ta? originally proposci system?

.A. -(qinor) Ine incra.isal conplexity of th: proposaa 71tornite 40 posar systam reducea its reliability reintive to taa-ori t i nally proposei onsite AC pow?r syatom. In general, th7 loss' complex 1 syst2m is, the mor likely it is to be 3012 to o?rform its ansignai tank. A 1933 complex systa.n-involv2s loa 2r octaati31 for'failur? of intervening hardware and I?ss t

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i-n:2* for coordination at autonatic an1 manual a ctions; as a lracul t , a'less conpl?x system is more reliabla. .4ar?over, be-caus2 of both-t.12 3 rester nu.noar of devices and tna increase.1 compl+4ity of .Tecassary proce$ures involv?3 in tne proposa.1 il tarna te 10 pauer system, it is subj2ct to 3 Jraatar potential

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for hu nan error in its lesign, implementation anJ operation, tato is tq2 originally propasci AC power system.

2 Does that conclude your testimony?

A. (All sitneasts) Yes.

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ATTACHMENT 1 l

u CONFIDENTIAL i ELEHEE gg e: G2orge Dennis Eley jddress: 117 Bortons Road Marlton, New Jersey 0805'3 3:::e Phone: (609) 768-6699 -

~ Business Phone: (609) 848-2913 geenses and c,-ti + i cat es : Combined First Class Certificate. of Competency Steamship & Motorship. Higher National -

Certificate in Mechanical Engineering.

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_eciety w -be-ships : - Associate Member of The Institute of Marine Engineers. Member of.the Institute of Port Engineers. Merber of the ASTM Task Group on Pollution' Abatement Equipment (F25.11).

M1 ope n t Winterv 19El - 1983 Marine Consultant with:-

Bead Office:- Ocean Transport and Trading PLC.

India Buildings Water Street Liverpool, Engla:id L20RB Telephone No 011-44-51-236-9292 Address of U.S.A. Office:-

Ocean Fleets Consultancy Service 1501 Grandview Avenue

- Midatlantic Corporate Center Thorefare, New Jersey 08086 Telephone Nos. (609) 435-6457 & (609) 848-2913 e

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r age 2 1969 - 1981: - Third Assistant, 2nd And Chief  !

Marine Engineer with above Co p y.

1966 - 1969: - Estimator and Contracts Engineer for British Shipbuilders at:-

Austin & Pickersgill Limited Shipbuilders and Installation Engineers P.O. Box 38 ,

j Southwick Sunderland Tyne & Wear, England Telephone Nos. 011-44-783-57684 1959 - 1966: - Apprentice Fitter & Turner, then Contracts '

Engineer with:-

George Clark & N.E.M., LTD.

P.O. Box 8 Northumberland Engine Works Wallsend, Northumberlan, England Telephone No. 011-44-966-623141 M~ of Work Eroerience & Accermlichmants 1.s a Marine Consultant with Ocean Transport & Trading, my' duties lave included:-

kgotiation and formation of a joint venture with the American hreau of Shipping to provide fuel services to the trarine industry.

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• responsibilities have been to negotiate with Senior . Officers of 125 and to formulate operational policy. My duties also include coordination of the various departments and efficient operation of the business. I have. implemented the Data Bank System for the cove business and control the staff so doing. I also act en'an 25ependent consultant on machinery damage investigations and run ser.inars for the following establishments on fuel technology.

I-) " Kings Point Merchant Marine Academy' on Professor Christenson's " Continuing Education on Diesel Technology" given to Chief engineers studying for advanced certification.

2.) Maritime Safety International lecturing 'to chief and port usineers on poor quality fuel oil.

-) ' Marine Encineers Benefit Association to chief and port Ofineers on p3or quality fuel oils.

W l Paga 3 In addition I advise on system design for ships enginerooms and upgrade existing vessel so that they have full operational capability on lower cuality fuel. I have worked in this capacity-with major American shipping companies and normally negotiate the centracts for so doing with the vice presi6ents of those l l

respective companies.

Prior to my employme'nt as a Consultant, I was employed by the same i co=pany for 12 years as a tiarine Engineer in all capacities up to the rank of Chief Engineer. In this capacity my responsibilities were for the efficient operation and maintenance of various diesel engines, boilers, air co=precsors, refrigeration systems which encompassed a high degree of automation. Coordination with different marine and hull classification societies was also a requirement as was the effective implementation of planned raintenance scheduling. .

Before continuing my career at sea, I was employed by British Shipbuil6ers as a Contracts Engineer. During this period, my responsibilities were to produce ships specifications for newbuildings to a potential owners requirements, and also to handle all ships contract correspondence. It was also my responsibility to estimate the costs of various building projects and submit these costs for negotiation with the owners representatives. .

Prior to my employment with British Shipbuilderc, I served an Engineering Apprenticeship with George Clark T N.E.M. LTD. , a Marine Enginebuilder. On ce=pletion of my apprenticeship I continued as a Draughtsman with this same company in the Engme Design Department until I was promoted to Contracts Engineer with duties similar to those held at British Shipbuilders.

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ATTACHMENT 2

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ATTACHMENT 2 EESilME NAME

Christopher John Smith ADDRESS

33173 Gillette Street Lake Elsinore, CA 92330 HOME PHONE: 714-678-4278 BUS. PHONE: 609-048-297.3 OUALIFICATIONS FIRST CLASS CERTIFICATE OF COMPETENCY " MOTOR"

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E3BHQHAL Ages ?8 years Height: 5'11" Weight: 160 lbs.

EITLQXMERI 1983 Marine Consultant with:

Ocean Fleets Services 1301 Metropolitan Avenue ,

Thorofare, New Jersey 08086 1970-1983 Served as Second Engineer on company vessels.

Responsible for the efficient operation of all main and auxiliary machinery.

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1 Resume Christopher John Smith 1967-1970 Served as Fourth and Third Engineer on company vessels.

1962-1967 Joined Ocean Flee's c and trained as an Engineer Cadet.

WORK EXPERIENCE During final year of apprenticeship spent several months in the company's engineering department designing engine room modifications for unmanned operation of machinery spaces of two classes of company ships.

Have stood.by the building of four of the company's ships in Japanese shipyards. This involved the checking and testing of most systems and

- machines in the machinery spaces and making modification recommendations where applicable.

Recently as a consultant, I have been advising a major American shiping company on the improved design and operation of their machinery on lower grade fuel.

JUSTERESTJi Aircraft maintenance, flying, and sky-diving.

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ATTACTMENT 3 PROFESSIONAL QUALIFICATIONS OF DALE G. BRIDENBAUGH DALE G. BRIDENBAUGH 1723 Hamilton Avenue Suite K San Jose, CA 95125 (408) 266-2716 EXPERIENCE:

1976 - PRESENT President - MHB Technical Associatec, San Jose, California Co-founder and partner of technical consulting firm. Specialists in energy consulting to governmental and other groups interested in evaluation of nuclear p?. ant safety and licensing. Consultant in this capacity to state agencies in California, New York, Illinois, New Jersey, Pennsylvania, Oklahoma and Minnesota and to the Norwegian Nuclear Power Committee, Swedish Nuclear Inspectorate, and various other organizations and environmental groupa. Performed extensive safety analysis for Swedish -

Energy Commission and contributed to the Union of Concerned Scientist's Review of WASH-1400. Consultant to the U.S. NRC - LWR Safety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural Resources Defense Council, and contributed to the Department of Energy LWR Sr.fety Improvement Program for Sandia Laboratories. Served as expert witness in NRC and state utility commission hearings.

1976 - (FEBRUARY - AUGUST)

Consultant, Project Survival, Palo Alto, California Volunteer work on Nuclear Safeguards Initiative campaigns in California, Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to civic, government, and college groups. Also resource person for public service pr2sentations on radio and television.

1973 - 1976 Manager, Performance Evaluation and Improvement, General Electric Company -

Nuclear Energy Division, San _, Jose, California Managed seventeen technical pad seven clerical personnel with responsibility for establishment and management of systems to monitor and

measure Boiling Water Reactor equipment and system operational performance. Integrated General Electric resources in customer plant modifications, coordinated correction of causes of forced outages and of efforts to improve reliability and performance of BWR systems.

Also responsible for development of Division Master Performance Improvement Plan as well as for numerous Staff special assignments on long-range studies. Was on special assignment for the management of two different ad hoc projects formed to resolve unique technical problems.

1972 - 1973 Manager, Product Service, General Electric Company - Nuclear Energy Division, San Jose, Californik Managed group of twenty-one technical and four clerical personnel. Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties. Also in charge of refueling and service planning, performance analysis, and service ,

communication functions supporting all completed commercial nuclear power resctors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland).

~

1968 - 1972 Manager,-Product Service, General Electric Company - Nuclear Energy Division, San Jose, California Managed sixteen technical and six clerical personnel with the responsibility for all customer contact, planning and execution of work required after the customer acceptance of department-supplied plants and/or equipment. This included quotation., sale and delivery of spare and renewal parts. Sales volume of parts increased from $1,000,000 in 1968 to crer

$3,000,000 in 1972.

~

1966 - 1968

!' Manager, Complaint and Warranty Service, General Electric Company - Nuclear Energy Division, San Jose, California Managed group of six persons with the responsibility for customer contacts,

~

planning and execution of work required after customer acceptance of department-supplied plants and/or equipment--both domestic and overseas.

1963 - 1966 Field Engineering Supervisor, General Electric Company, Installation and Service Engineering Department, Los Angeles, California Supervised approximately eight field representatives with responsibility for General Electric steam and gas turbine installation and maintenance l

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work in Southern California, Arizona, and Southern Nevada. During this period was responsible for the installation of eight different central station steam turbine-generator units, plus much maintenance activity.

Work included customer contact, preparation of quotations, and contract negotiations.

1956 - 1963 Field Engineer, General Electric Company, Installation and Service Engineering Department, Chicago, Illinois Supervised installation and maintenance of steam turbines of all sizes.

Supervised crews of'from ten to more than one hundred men, depending on the job. Worked primarily with large utilities but had significant work with steel, petroleum and other process industries. Had four years of experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial nuclear power unit.

1955 - 1956 Engineering Training Program, Genercl Electric Company, Erie, Pennsylvania, and Schenectady, New York Training assignments in plant facilities design and in steam turbine

, testing at two General Electric factory locations.

1953 - 1955 United States Army - Ordnance School, Aberdeen, Maryland Instructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

I 1953 Engineering Training Program, General Electric Company, Evendale, Ohio Training assignment with Aircraft Cas Turbine Department.

EDUCATION & AFFILIATIONS:

BSME - 1953, South Dakota School of Mines and Technology, Rapid City, South Dakota, Upper 1/4 of class.

Professional Nuclear Engineer - California. Certificate No. 0973.

Member - American Nuclear Society

= - _ _ .

I Various Company Training Courses during career including Professional Business Management, Kepner Tregoe Decision Making, Effective Presentation, .

and numerous technical seminars.

HONORS & AWARDS:

Sigma Tau - Honorary Engineering Fraternity. .

General Managers Award, General Electric Company.

PERSONAL DATA: 1 Born November 20, 1931, Miller, South Dakota.

Married, three children 6'2", 190 lbs., health - excellent Honorable discharge from United States Army Robbies: Skiing, hiking, work with Boy Scout Groups PUBLICATIONS & TESTIMONY:

1. Operating and Maintenance Experience, presented at Twelfth Annual Seminar for Electric Utility Executives, Pebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.

2, Maintenance and In-Service Inspection, presented at IAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plants, Bridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.

3. Operating and Maintenance Experience, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, January, 1974.

4. Improving Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, January,1974.

5. Application of Plant Outage Experience to Improve Plant Performance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974.

6. Nuclear Valve Testing Cuts Cost, Time, Electrical World, October 15, 1974.

7. Testimony of D. G. Bridenbaugh, R. B. Hubbard, and G. C. Minor before the United States Congress, Joint Committee on Atomic Energy, February 18, 1976, Washington, D.C. (Published by the Union of Concerned Scientists, Cambridge, Massachusetts.)

8. Testimony of D. G. Bridenbaugh, R. B. Hubbard, G. C. Minor to the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

9. Testimony by D. G. Bridenbaugh before the California Energy Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency Planning, Avila Beach, California, November 4, 1976.

10. Testimony by D. G. Bridenbaugh before the U. S. Nuclear Regulatory Commission, subject: Diablo Canyon Nuclear Plant Performance, Atomic Safety and Licensing Board Hearings, December, 1976.

11. Testimony by D. G. Bridenbaugh before the California Energy Commission, subject: Interim Spent Fuel Storage Considerations, March 10, 1977.

12. Testimony of D. G. Bridenbaugh before the New York State Public Service Commission Siting Board dearings concerning the Jamesport Nuclear Power Station, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April, 1977.

13. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject: Decommissioning of Pressurized Water Reactors, Sundesert Nuclear Plant Hearings, June 9, 1977.

14. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject: Economic Relationships of Decommissioning, Sundesert Nuclear Plant, for the Natural Resources Defense Council, July 15, 1977.

15. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400, Kendall, Hubbard, Minor & Bridenbaugh, et al, for the Union of Concerned Scientists, August, 1977,

16. Testimony by D. G. Bridenbaugh before the Vermont State Board of Health, subject: Operation of Vermont Yankee Nuclear Plant and Its Impact on Public Health and Safety, October 6, 1977.

17. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board, subject: Deficiencies

-in Safety Evaluation of Non-Seismic Issues, Lack of a Definitive Finding of Safety, Diablo Canyon Nuclear Units, October 18, 1977, Avila Beach, California.

18. Testimony by D. G. Bridenbaugh before the Norwegian Commission on j

. Nuclear Power, subject: Reactor Safety / Risk, October 26, 1977. '

19. Swedish Reactor Safety Study: Barseback Risk Assessment, MHB I Technical Associates, January, 1978. (Published by the Swedish Department of Industry as Document.Ds1 1978:1) ,

20. Testimony by D. G. Bridenbaugh before the Louisiana State Legislature Committee on Natural Resources, subject: Nuclear Power Plant

. Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.

21. Spent Fuel Disposal Costs,. report prepared by D. G. Bridenbaugh for i

the Natural Resources Defense Council (NRDC), August 31, 1978.

22. Testimony of D. G. Bridenbaugh, G. C. Minor, and R. B. Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox Nuclear Power Station Construction Permit Hearings, September 25,

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1978, Tulsa, Oklahoma.

23. Testimony of D. G. Bridenbaugh and R. B. Hubbard before the Louisiana

+ Public. Service Commission, Nuclear Plant and Power Generation Costs, November 19, 1978,- Baton Rouge, Louisiana.

'24. Testimony by D. G. Bridenbaugh before the City Council and Electric Utility Commission of Austin, Texas, Design, Construction, and Operating Experience of Nuclear Generating Facilities, December 5, 1978, Austin, Texas, i 25. Testimony by D. G. Bridenbaugh for the Commonwealth of Massachusetts,

! Department of Public Utilities, Impact 'of Unresolved Safety Issues, L Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost at the Proposed Pilgrim-2 Nuclear Plant, June 8, 1979..

l 26. Improving the Safety of LWR Power Plants, MHB Technical Associates,

, prepared for U.S. Dept. of Energy, Sandia Laboratories, September 28, 1979.

27. BWR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish p Nuclear Power Inspectorate (SKI), October, 1979, f' 28. Uncertainty in Nuclear Risk Assessment Methodology. MHB Technical L

Associates, for the Swedish Nuclear Power Inspectorate (SKI), January 1980.

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29. Testimony of D. G. Bridenbaugh and G. C. Minor before the Atomic Safety and Licensing Board, in the matter of Sacramento Municipal Utility District, Rancho Seco Nuclear Generating Station following TMI-2 accident, subject: Operator Training and Human Factors Engineering, for the California Ener,gy Commission, February 11, 1980.

30. . Italian Reactor Safety Study: Caorso Risk Assessment, NHB Technical Associates, for Friends of the Earth, Italy, March, 1980.

31. Decontamination of Krypton-85 from Three Mile Island Nuclear Plant, l' H. Kendall, R. Pollard, & D. G. Bridenbaugh, et al, The Union of Concerned . Scientists, delivered to the Governor of Pennsylvania, May 15, 1980.

32. Testimony by D. G. Bridenbaugh before the New Jersey Board of Public

' Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage. August, 1980.

33. Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, for Minnesota Pollution Control Agency, September,-1980.

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34. Position. Statement, Proposed Rulemaking on the Storage and Disposal of Nuclear Waste, Joint Cross-Statement of Position of the New England Coalition on-Nuclear Pollution and the Natural Resources Defense Council,' September, 1980.

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35. Testimony by D. G. Bridenbaugh and G. C. Minor, before the New York State Public Service Commission, In the Matter of Long Island Lighting Company Temporary Rate Case, prepared for the Shoreham Opponents k

Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.

L 36. Supplemental Testimony by D. G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Department of the

'Public Advocate, Division of Rate Counsel,-Analysis of 1979 Salem-1 Refueling Outage , December,1980.

p l 37. Testimony by D. G. Bridenbaugh and G. C. Minor,.before the New Jersey Board of Public Utilities, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Oyster' Creek 1980 Refueling Outage Investigation, February 1981.

38. Economic Assessment: ' Ownership Interest in Palo Verde Nuclear Station, KHB Technical Associates, for the City of Riverside, September 11, 1981.

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- 39. . Testimony of D. G. Bridenbaugh before the Public Utilities Commission of Ohio, in the Matter of the Regulation of the Electric Fuel

-Component Contained Within the Rate Schedules of the Toledo Edison Company and Related Matters, subject: Davis-Besse Nuclear Power Station 1980-81 Outage Review, November, 1981.

40.- Supplemental. Testimony of D. G. Bridenbaugh before the Public Utilities Commission of Ohio, in the matter of the Regulation of the Electric Fuel Component Contained within the Rate Schedules of the 1 . Toledo Edison Company and Related Matters, subject: Davis-Besse

!. Nu'elear Power Station 1980-81 Outage Review, November 1981.

Systems Interaction and Single Failure Criterion, Phase 2 Report, MHB

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41.

+ . Technical . Associates for the Swedish Nuclear Power inspectorate (SKI),

January, 1982.

42. . Testimony of D. C. Bridenbaugh and G. C. Minor on behalf of Governor Edmund G. Brown Jr...before the Atomic Safety and Licensing Board, regarding Contention 10, Pressurizer Heaters, January 11, 1982.

43. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Governor Edmund G. Brown Jr., before the Atomic Safety and Licensing Board, regarding Contention 12, Block and Pilot Operated Relief Valves, January 11, 1982.

44. Testimony of D. G. Bridenbaugh before the Commonwealth of Massachusetts, Department of Public Utilities,' on behalf of the

. Massachusetts Attorney General, Pilgrim Nuclear Power Station, 1981-82 Outage Investigation, March 11, 1982.

45. Testimony of D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocate,.

-Beaver Valley Outage, March, 1982.

. 46. Interim testimony of D. G. Bridenbaugh before the Illinois Commerce

[

Commission, on behalf of the-Illinois Attorney General's Office, Expected Lifetimes and Performance of Nuclear Power Plants, March, 7

1982.

Il 47. Testimony of D. G. Bridenbaugh and G. C. Minor before the Atomic

[

Safety and Licensing Board, on behalf of Suffolk County, in the matter

! -of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 7

1, regarding Suffolk County Contention 11, Passive Meenanical Valve Failures, April 13, 1982. _

48. Testimony of D. G. Bridenbaugh and R. B. Hubbard, in the Matter of Jersey Central Power and Light Company For an Increase in Rates for Electrical Service, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Three Mile Island Units 1 &

2, Cleanup and Modification Programs, May, 1982.

l l

l- - - - - .- .- . - - . . . - - . - . - . . -- --. _ . - .-. - _ -_ - - - -. - -

l

49. ITestimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk

-County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 22, SRV Test Program, May 25, 1982.

50. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding'Suffolk County Contention 28(a)(vi) and SOC Contention

- 7A(6 ), Reduction of SRV Challenges, June 14, 1982.

51 '. Testimony of D. G. Bridenbaugh before the Illinois Commerce Commissier, on behalf of the Illinois Attorney General's Office, l Expected Lifetimes and Performance of Nuclear Power Plants, June 18,

'1982.

'52. Testimony o'f D. G. -Bridenbaugh and R. B. Hubbard on behalf of the Ohio Consumers Counsel, before the Public Utilities Commission of Ohio, regarding Construction of. Perry Nuclear Generating Unit No. 1, October 7, 1982.

53. Issues Affecting the Viabiling and Acceptability of Nuclear Power Usage in the United States, prepared by MHB Technical Associates for Congress of the United States, Office of Technology Assessment for use

.in conjunction with Workshop on Technological and Regulatory Changes

'in Nuclear Power, December 8 & 9, 1982.

- 54. Testimony of D. G.-Bridenbaugh on behalf of Rockford League of Women Voters, before the Atomic Safety and Licensing Board, in the matter of Commonwealth Edison Company, Byron Station, Units 1 and 2, regarding _

Contention 22, Steam Generators, March 1,1983.

55. Testimony 'of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of.the Office of Consumer.

Advocate, Regarding the Cost of Constructing the Susquehanna Steam Electric Station, Unit I, Re: Pennsylvania Power and Light, March 18, 1983.

56. .Surrebuttal Testimony of D. G. Bridenbaugh before-the Pennsylvania

-Public Utility Commission, on behalf of the Office of Consumer

-Advocate, Regarding the Cost of Constructing the Susquehanna Steam-Electric Station, Unit I, Re: Pennsylvania Power and Light, April 20,.1983.

57. _ Testimony of 'D.' G. Bridenbaugh In the Matter of Public Service Gas &

Electric, Base Rate Case, Nuclear Construction Expenditures,' on behalf of New Jersey Department of the Public Advocate, Division of . Rate Counsel, October 13, 1983 .

-9_

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58. Affidavit of D. G. Bridenbaugh, in the Matter of Jersey Central Power and Light, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, THI Fault Investigation, November 23, 1983.

59. Testimony of D. G. Bridenbaugh, in the Matter of Public Service Electric & Gas, on behalf of New Jersey Department of the Public Advocate, Diviraun of Rate Counsel, LEAC Investigation, Salem-1 Outages, December 1, 1983.

60. Rebuttal Testimony of D. G. Bridenbaugh, in the Matter of public Service Electric & Gas, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, LEAC Investigation, Salem-1 Outages, January 18, 1984.

61. Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G.

C. Minor before the State of New York Public Service Commission, PSC Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investigate the Cost of the Shoreham Nuclear Generating Facility -- Phase II, on behalf of County of Suffolk, February 10, 1984.

62. Status Report, WJ Zimmer Plant, Assessment of Options, MHB Technical Associates, prepared for The Ohio Office of the Consumer's Counsel, February 23, 1984.

9

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Attachment. 6 is a photograph of facilities within the-boundaries of the Shoreham site.

Due to. concerns of LILCO, circulation of Attachment 6 'has been restricted. At the hearing, copies will be provided for the use of the Licensing Board, parties and witnesses.

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ATTACHMENT 7

" Attachment 7 is a photograph'of facilities

. within-the boundaries'of the-Shoreham site.

Due to concernsLof LILCO, circulation of Attachment 7 has been~ restricted. At the hearing, copies will be provided :for the -

use of-the' Licensing Board, parties and

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- Attachment 8 is a-photograph of facilities

- within the boundaries of the Shoreham site.

Due'to concerns of LILCO, circulation of Attachment 8 has been restricted. At the hearing, copies will be provided for the use of the Licensing Board, parties and witnesses.-

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ATTACHMENT 9 S

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Attachment 9 is a photograph of facilities within the boundaries of the Shoreham site.

Due to concerns of LILCO, circulation of Attachment 9 has been restricted. At the hearing, copies will-be provided for the i: use of the Licensing Board, parties and witnesses.

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TP Number 24.307.04 Revision G Date E f. s-/,r /f4 TPC N - M I 4 - cLi S. f i~. 4 . j u d . -G - { ,)

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TPC BI-WEEKLY TESTING OF G. M.

MOBILE DIESEL GENERATORS 1.0 PURPOSE To provide detailed steps necessary to perform the required surveillance testing as set forth by LILCO commitments and to provide additional

! assurances of the highest reliable A.L. power supply for Shoreham.

2.0 RESPONSIBILITY The Operating Engineer shall be responsible for ensuring proper implemen-tation of this procedure.

SR2-1021.200-6.421 I ,[%i -]Tf75 pg ..

l i.dd]l,i LLlj L;U}9 l JUN 071984

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1 of 1 B1-WEEKLY TESTING OF GM MOBILE DlESEL GENERATOR UNIT # 4 Signature Initials Time Date Authorization for Start Initiated By Co=pleted By Revi.ewed By Initials Step Procedure

1. Verify Prerequisites Have Been Met

2. Place Selector Switch (ACB 4 Cubicle Door) to Idle Allow Engine to Idle for approx. 90 secs.

(90 Sec TD Before High Speed Operation permitted)

NOTE: NEXT SIEP STARTS THE DIESEL GENERATOR # 4

3. Place Start /Stop Switch to Start

4. Place Selector Switch to Run Engine will accelerate to 900 rpm

5. Place Selector Switch to " Excite" Position

' Observe Generator Volts increase

6. Adjust Generator Voltage with Voltage Control Switch (Only Generator Voltage indicated, no Bus Voltage Check with C. R. for Bus Voltage)

7. Adjust Engine Speed with the Governor Control Switch (Set Indicator to 60 Hertz)

8. Using Synch. Lights on Main Control Cabinet, Close ACB f/4 at Point of Complete Darkness

9. Increase Load to Approximately 225 amps

10. After Run is complete, Shutdown Diesel by Lowering Load to approx. 40 amps with Governor Control Switch

11. Open Generator ACB #4 r

12. Place Start /Stop S itch to stop

13. Place Selector Switch to Auto TPF 24.367.f4-4 Rev. 0 -

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Attachment 11is a photograph of facilities within the boundaries of the Shoreham site.

Due to concerns of-LILCO, circulation of Attachmen,t 11 has been restricted.

! At the hearing,. copies will be provided for the use of the Licensing Board, parties and witnesses.

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ATTACHMENT 12 EMD 401 (UTEX Engine at 6030 hours0.0698 days <br />1.675 hours <br />0.00997 weeks <br />0.00229 months <br />)

Hours:

11601 New Radiator 11618 New Cylinder Head (9) Crkd 11880 New Power Pack (4) Head Crkd 12242 New Cylinder Heads (8.18) Crkd 12274 New Cylinder Head (2) Crkd 12400 New Power Assy (20) 12498 New Clock 12695 New Power Assy (6, 9, 11, 19) 12932 Repower 12938 New Starters 13019 New Power Assy (4, 6, 10, 11, 13, 18) 13019.25 New Power Assy (11) 13234 New Frequency Generator 13290 New Left Rear Camshaft 13290 Report of Installation Insnection at Shoreham states that water pumps need replacing.

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i ATTACHMENT 13 l

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ATTACHMENT 13 EMD 402 (UTEX Engine at 6552 hours0.0758 days <br />1.82 hours <br />0.0108 weeks <br />0.00249 months <br />)

Hours:

10834 New Rear Radiator Core 11279 New Set Batteries 11727 New Cylinder Head (6) Crkd 11437 New Power Assy (19) 12697 New Stack 12899 New Cylinder Head 12737 New Power Assy (1) 12846 Camshaft Showing Wear 12846 Report of Installation Inspection at Shoreham states that engine components are used and approaching overnaul.

Recommend monthly surveillance to in-spect and advise LILCO of any abnormal

- conditions.

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j, ATTACHMENT 14 EMD 403 (UTEX Engine at 6163 hours0.0713 days <br />1.712 hours <br />0.0102 weeks <br />0.00235 months <br />)

-Hours:

11062 New Cvlinder Head (2) Valve Blow

.11310- New Right Front Camshaft 11306 New Power Assy (19) 11306 New _

Cylinder Head (9) 11563 New LH Water Pump ,

11632. New Cylinder Head (19)

'11695 New Cylinder Head (14) 11822' New Starting Motors 11868 New Cylinder Head (4) Crkd-11892- New Cvlinder Head (12) 11980 New Viscous Damner 11980 Two New Water Pumos 11980 New Assv Drive Gear 11980 New Scavence Pumo Gear 11980 New Main Bearing Pump Gear 11980~ New Governor Drive Gear 12170 New Cylinder Head (3.6) Valve Blow 12532 Nev Power Assy (17) 12511 New Cylinder Head (20) 12694 New Starting Motors -

12922 Replaced Power Assy (1) Used Unit 12952 New Starting Motors 13074 Replaced Power Assy (16) Used Unit 13152 Repower 13152 New Turbocharger 13152 New R Cooling Water Pump 13177- Recommendation for Prelube Before Starting 13286 New Power Assy (5, 15) Scored

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ATTACHMENT 15 i

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ATTACHMENT 15 EMD 404 L (UTEX Engine at 8070 hours0.0934 days <br />2.242 hours <br />0.0133 weeks <br />0.00307 months <br />)

Hours:

9407 New Generator and Dust Bin Blower (Failure)

'10992 New Turbocharger (Failed) 11540 New Starter Motor 11540 New Frequency Generator 11601 New Lower Starter Motor 11617 New Upper-Starter Motor

-_11617 New Frequency Generator 111617 New Upper and Lower Starter Motor 11617 New Power Assy (11, 13) 11696 New Turbocharger (Failed) 11696 Two New Aftercoolers (Damaged by Turbo Fail) 11696 New. Cylinder Head (9, 10) Valve Blow 12781 New Left Water Pump 12781. New Governor 13047 New R&L Water Pumps 13047 Camshaft Showing Wear 13047 Report of Installation Inspcction at Shoreham states that engine components are used and approaching overhaul.

Recommend monthly surveillance to inspect and advise LILCO of any abnormal condition.

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i ATTACHMENT 17 4

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. Attachment 17 is a photograph of facilities within the boundaries of the Shoreham site.

- Due to concerns'of LILCO, circulation of

- Attachment '17 has been restricted. ~ At the

- hearing, copies will be provided for the use of the Licensing Board,~ parties and witnesses.

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