ML20093F471
| ML20093F471 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/16/1984 |
| From: | Bridenbaugh D, Hubbard R SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20093F417 | List: |
| References | |
| OL-4, NUDOCS 8407190250 | |
| Download: ML20093F471 (219) | |
Text
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~~~ CO. r-W.: ai4DENCE UNITED STATES OF AMFRICA NUOLEAP. REGULATORY COMMISSION
- RFFOPE THE ATOMIC _SAi'ETY AND LICENSING ~ BOARg;re
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LInLthe. Matter of )
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CCNilN LONG EISLAMD LIGHTING COMPANY )* Docket No. 5 83327-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, )
-Unit'1)'
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DIRFCT TESTIMONY OE'
'DAL? G. BRIDENBAUGH'AND RICHARD B. HUBBARD ON BEHALF 0F SUFFOLK COUNTY-I. INTRODUCTION 0: Mr .' ; Brid enhaugh, please state your name, address, occupation and professional qualifications.
I A: My name is Dale G. Bridenbaugh, and my business address is 1723 Hamilton Avenue, San Jose, California. .I am
, president of MHB Technical Associates. My qualifications are' attached hereto as Attachment 1.
'Q: Mr. Hubbard,'please' state your name, address, occupation and professional qualifications.-
A: My name is Richard B.-Hubbard, and my business address is 1723 Hamilton Avenue, San Jose, California. I am vice-president of MHB Technical Associates. My qualifications are attached hereto as Attachment 2. 8407190250 840716 PDR ADOCK 0500032 T u
1 ( -- p. 4 I II. PURPOSE OF TESTIMONY 0: What is the purpose of your testimony? A: LILCO has sought an exemption from NRC regulations to permit low power operation in advance of any FRC decision on the-adequacy of its onsite emergency diesel generators. W
.Under 10 CPR 650.12(a) and the NRC's May 16, 1984 decision (CLI-84-8), a relevant consideration is whether the public interest and a balance of the equities are in favor of the grant of an exemption. Further, in its May 22 Application
'for Fxemption, LILCO has expressed the view that it is only due to problems arising during preoperational testing of the-Transamerica DeLaval, Inc. ("DeLaval") diesels that
.the diesels have not yet been licensed. See Application gk for Exemption at 25.
.The-purpose of'our-testinony is to summarize the results
- of an invest'igation we have undertaken into the. facts and circumstances involving LILCO's selection and procurement of the DeLaval emergency diesel generators (" diesels") and of-the actions taken by LILCO in conjunction with the failures subsequently experienced 'with these engines.
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.be serious. problems" th the DeLaval diesels. In our
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[/7 ^ at.an earlygdate and should have'taken steps'.to ensure e 's N , aaj -,. that. reliable d.iesels were procured. LILCO failed to take -0/.:f-1 t jQ ~ (i.) Nt such steps. 'Stich steps would have been to (i) commence a w - gx s.
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l complete design -eview and revalidation program far in t . advance: of the September' '1963 date when such' a program ac-t
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- 4. repair and/or qualification of the.DeLaval diesels in a
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4,NQ -timely manner which.would not necessitate application for O
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, $' . an exenption; or (ii) to procure repla' cement diesels at a-Jt
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~ -instead of the Summer of 1985 when the. Colt diesels are s e, , 3 . ,.4 . s -scheduled to.be ready. Accordingly, it is our opinion 'y, 3 s s
}that_it would not be.in the 'public interest and that a s
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s reason that LILCO now seeks an exemption is because of its own failure to take reasonable steps to ensure procurement of reliable diesels at an earlier time. O: Prior to seeking an exemption, how did-LILCO propose to comply with GDC 17 during low power operation? A: -Since January 1976 when the Shoreham FSAF first came out, LTLCO .has always relied .for onsite emergency AC power on three DeLaval diesels. These diesels, as will be
. discussed later in our testimony, were ordered from DeLaval in 1974 and arrived at Shoreham in 1976. They were stored for some period of time, and then installed.
Turnover to the startup organization for testing occurred in August.1980 for Diesel Generator 102, .and in October - 1991'for Diesel Generators 101 and 103. Intensive preoperational testing began in September.1982.1/
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, f. +'. , i e' gey j O: Tn a previous answer you referenced an investigation of h: 7 y . LILCO's, handling of issues related to the DeLaval diesels.
.e m 3 .i.~ Please exp1ain.
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We submit,ted writtyn testimony on February 10, 1984 in the h= h ongoin%ypoceeding be. fore }the New York Public Service i ,, ; ' ,. .
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t y ',,,? , Commission in: PSC Case No. ?7563 (Phase II), a case
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. f; g; y ; des 19ngd tc.qinvestigate the co,st of Shor.eham. The purpose y ?..
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x,d 7 aJanuncy 1984 est[ mate of $3.877 billion'or more. w, In
' '%<? - hsb : $ ', Q e s n N ty1'eparing? that testimony, we evaluated the amount of the cy -
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[ 77:%ostfincr' ease that- is attributa'ble,to.LILCO's' allegedly f -t . - y; R f j ' ' ' ' g a[ -6 . . i rep l/?'ihpruIdenU/ resp 6rfscs dci, ;rig;u.ptory[ E
'desigd, and technical
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Among;t $ issues addressed [sas how the cost of
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* .7 Rhoreham.was a f fectsp bp.,LILCO'si I rocurement, installa-g 7,'
tiorf, and ' test ' ng of[> he fjeLaval d(esels . , I'% ' . ,A < , ; ]p.7,y.M <;, rf;- a v ug. ', j - ) r r. <
.--y d: ,hgd.s-.. ' i , s[? hour investigation concerning the[ costs incurred at ~
1_e - ..,,,.- :- s M 3,... - p oreham consisted' primarily of our' participation in the f'
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We Meviewed documents g, +% ~% r-u y#W MP . . provided to Suf folk County and the 'Publ:jc Service , ;ft :f w g ,
' WM 7 [ . Commission Staff by 1;ILCO. In,,pdditiorii ve assisted e x ~ ~ '
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.Suffolk' County in the preparation of interrogatories and I
reviewed LILCO's responses to them. MHB representatives p also attended and participated in many of the interviews that the Public Service Commission Sta f f and its consul-tants conducted with employees of LILCO and Stone and Webster (LILCO's Contractor Architect-Engineer). i; In addition to our role.in the discovery and testimo-ny7 phase of the. Phase II proceeding, . Gregory Minor and Dale Bridenbaugh of MPB also provided testimony regarding the likely cost and schedule to complete Shoreham in Phase I of thatJproceeding.- Finally, since 1977 MHB has been consultant to .Suffolk County in the Atomic Safety and
. Licensing ~~ Board proceeding to determine'Whether LILCO has
-met =theTrequirements necessary to receive an Operating License, participating actively in the DeLaval diesel pro-ceeding, among'others.
III. LILCO'S'IhERGENCY DIESEL GENERATOR PROBLEMS 0: ' Briefly describe the major -problems LILCO has encountered
.recently with it's DeLaval-diesels.
- A: ..The.three DeLaval. diesels at Shoreham have experienced re-peated deficiencies as set forth herein and in the
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wt - p .- Attachments. For example, operational problems-with the diesels-at Shoreham occurring a relatively short time prior 3to the August 1983 crankshaft failure included cyl-
-inder' head cracks, rocker arm assembly hold-down bolt
' failures, turbocharger bearing failures, and cracks in the lengine block casting. Further, LILCO was fined $40,000 by
-the NRC during 19f for its failure to follow required procedures during the preoperational testing of the die-sels.
On August 12, 1983, during the testing of replace , ments. for cylinder heads that had cracked, one of the
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'three diesels, 102, experienced excessive vibration and erratic load. swings. On August 13, 1983, it~was discoveredithat the crankshaft on diesel'102 was com-t pletely severed'. During disassembly of the diesels, the -
crankshafts of the other two diesels were found to contain cracks. In addition, following the crankshaft failure in August 1983, other problems were subsequently revealed,
' including cracked connecting rod bearings and pistons.2/
I h 2 /. .Millard'S. Pollock 6.o Harold R. Denton, Nov. 23, 1983,
-SNRC-986.
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u Ultimately, 23 of 24 pistons in the Shoreham engines were found to be cracked.3/ In Fall, 1983, following " a crankshaft failure, and in recognition.of other operational deficiencies as set forth
.later-herein which have occurred with DeLaval diesels, LILCO instituted a recovery program aimed at determining
.the cause of the crankshaft failure, correcting it, and attempting to ensure that other components of the Shoreham
- diesels would operate reliably in the future.4/ In our opinion, this-recovery program'came far too late in time.
6: Nere the recent DeLaval problems you just described a complete surprise or-were these problems-to have been ex-pected? y L t , 3f LILCO' Diesel Generator Status-Report, November 17, 1983. 14/~ Brian R. McCaffrey'to Harold R. Denton, January 6, 1984, Shoreham Diesel Generator Recovery Program Summary, SNRC-LOO 3. The NRC has al-so recognized the need for such a recovery program. Indeed, ,he NRC determined that a
. broad pattern of deficiencir.s in critical engine compo-nents has become evident at Shoreham and at other nuclear and-non-nuclear facil*ities employing DeLaval diesels. The
' NRC now believes that the- deficiencies stem from 11nadequacies in design, manufacture and quality control by DeLaval. Order Requiring Diesel Generator Inspection,"
Grand Gulf Nuclear Station, Docket No. 50-416, May 22,
'1984. '(In particular, see Attachment 4 thereto.)
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A: . :The preciseJproblems or failures which have been experi-i enced in the Shoreham DeLaval diesels in the_last year and a-half were:perhaps not expected. However, given prior events related to the diesels, serious. problems cannot be deemed tochave been a surprise. Indeed, the reported
'cau'se of_the current problems-(discussed later in this t'estimony) can'be traced.directly to failures that occurred early in the' design and manufacturing process.5/
I): 1How do these problems relate to LILCO's Application
. For Exemption?
5/) For example, LILCO retained Failure Analysis Associates (" Failure-Analysis") to investigate the August 1983 crank-
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- sha ft failure.- : Failure Analysis concluded that the crank-shaft failed because it.was not designed to withstand the
- cyclic torsional stresses that would be experienced during the diesels' operation. The conclusion was reached, based on a relatively simple' calculation, that DeLaval had
'misdesigned the crankshaft, leading to insuf.ficient capac-ity to withstand anticipated loads. Emergency Diesel Gen-erator -- Cranksha f t Failure Investigation, ' Failure Analysis, October 31, 1983.
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LILCO attributed the crankshaft problem to a design error in-the torsional stress analysis performed by DeLaval. LILCO Diesel Generator Status
-Report,1 November.17, 19R3. 'As will be addressed later in this testimony, the LILCO and Ston* and Webster audit of DeLaval in 1975 did not even address the crucial area of design control. If it,had, perhaps the design deficiency in the crankshaft would have been a notice of the need for a thorough design review.
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A: It~is our' position that LTLCO was, in effect, responsible
' for failing 'to detect these deficiencies and for failing s at a far earlier date (i.e., well in advance of Fall 1993) to institute necessary steps to repair (if possible) or replace the DeLaval diesels. Thus the need for LILCO now
'to seek an exemption is really the result of LILCO's own fault. Indeed, as set forth in the following portions of this testimony, our review indicates that from 1974 to 1983, LILCO's approach has been to treat the symptoms rather than the root cause(s) underlying the problems dis-closed-in the design and fabrication of the Shoreham die-sels. Thus, there have been repeated problems with these diesels which put LILCO on notice far before Fall 1983 Tthat something was fundamentally wrong with its diesels.
LILCO. ignored the warning-signs and never sought to deter-mine adequately 1why the problems existed. The need for LILCO now to seek an exemption is a direct result of
.LILCO's failure to detect and remedy.in a timely manner
-the' broad pattern of deficiencies in the design and manufacture of the DeLaval diesels.
O:- Dies the. fact ~ that LILCO initiated a program in Fall 1983 to attempt tx) mitigate and correct the problems with the f DeLaval diesels change your opinion that LILCO's need for 3 b
an exemption is a result of LILCO's own failure to take appropriate actions at an earlier date? A: : No . - The fact:that LILCO has eventually begun to attempt
.to deal with the difficult _(perhaps insurmountable)
DeLavalfdiesel problems does not make its prior failure to act any~1ess the cause of the problem in the first place. Our point is'that it is not in the public interest, and it is.not equitable to reward a utility by waiving a compul-sory safety-regulation, when the reason the utility is un-
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~ able to comply with that regulation is a result of.its own insufficient actions.
0: When did LILCO first become aware of the potential for serious deficiences relating to the DeLaval diesels? A: In-1974 LILCO was on notice that heightened QA/OC audit treatment of DeLaval would be necessary to ensure that a reliable and top quality product would be designed and
.manu fa ctured . In fact, however, despite obvious warning signals, LILCO and Stone and Webster failed to implement an . adequate QA/QC audit program for the design and manufacture of the DeLaval diesels.
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0: Please state the basis (es) for your prior answer. A: The diesels supplied for Shoreham were DeLaval's first i ever contract for supply of a diesel for a nuclear appli-cation. To the best of our knowledge, DeLaval had never i l
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even attempted to develop or implement a 10 CFR 50 Appen- l dix B - OA program before .1974. DeLaval's newness to nucle- l ar work and_ Appendix B OA matters, in our opinion, made it incumbent on LILCO or its delegate to pay close attention, from the beginning, to:how well DeLaval was doing in de-signing and manufacturing the Shoreham diesels. Indeed, the fact that DeLaval was new to the nuclear field made it absolutely incumbent ~on LILCO to ensure that a strirgent audit program was instituted to ensure that all nuclear requirements were met. In fact, however, LILCO did not institute such a program.I/ 6/
- Since the Shoreham diesels were DeLaval's first attempt to design and manufacture diesels pursuant to the regulatory requirements of Appendix A Jand Appendix B to 10 CFR Part 50, LILCO and Stone and Webster should have anticipated
" hugs" in the DeLaval QA program. Thus, Stone and Webster
-should.have increased its audits of DeLaval activities during the design and- fabrication of the Shoreham diesels
,because~the need to detect and correct the " bugs" in the
'DeLaval CA/OC process was obvious. LILCO's failure to as-sure that this was done is another basis for our belief
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that LILCO's .present need for the requested exemption is its own fault.
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4 The purchase order for the DeLaval diesels was issued
-hyjLILCO in May 1974 following a OA survey of the DeLaval shop conducted by Stone and Webster on February 26, b 1974.7/ -Mue-DeLaval OA manual had been reviewed by Stone and Webster one week earlier (on February 19, 1974) and had been found not to meet several of the regulatory re-quirements of Appendix B to 10 CFR Part 50. The major deficiencies discovered by Stone and Webster were that design control and a number of measures for vendor correc-ti've1 action,.QA record retention, and audits, were not' addressed in the DeLaval manual.8/ It was not until March L. 14, 1974)~that Stone and Webster determined that the 1DeLaval OA manual, as revised on March 1, 1974, was in compliance with the intent of 10 CFR Part 50, Appendix B.
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Based on the preceding, we conclude that the Stone and Webster shop survey should have put Stone and Webster and LILCO even more on alert .(aside from DeLaval's lack of nuclear experience) in early 1974 of the need ts closely watch DeLaval's OA implementation. They did not. [7/ Stone and Webster Procurement Quality Control Survey of DeLaval, G. I. Beaman, February 26, 1974.
.8/
Stone and Webster. Manual Checklist, DeLaval QA Manual dated May 1, 1970, Ellen O'Connor, February 19, 1974. m..
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The fact that the February 1974 shop survey was conducted on a OA manual and program which were in transi-tion should have led to a new survey and audits of OA implementation shortly after March 14, 1974 when the OA manual was found to be adequate or shortly after May 1974 when.the purchase order was issued. This would have allowed an early judoment, during the key diesel design phase, regarding whether essential OA functions were being
- properly performed . LILCO failed to do any such audits in
- a. timely manner.
Stone & Webster._did, much later, conduct an audit of DeLaval.. However, .the audit findings, the time of the audit, its scope, and the lack of additional audits, support our view that LILCO should be deemed to be respon-sible for the difficulties with the DeLaval diesels. This one audit-of DeLaval by Stone and Webster was not conducted-until October-28 to 30, 1975, more than 18 p imonths after the. initial shop survey.that found DeLaval-OA to be deficient and about 18 months'after the purchase order had been~placed. Reaudits of the corrective action
; measures required of: DeLaval as a result-of the October 1975 audit were' performed on February 23, 1976 and June
~18, 1976. In both the 1975 aud3t report and the February
1 reaudit, Stone and Webster auditors concluded that DeLaval had failed to fully comply with the requirements set forth
'in.its OA manual or with the regulations in Appendix B to 10 CFF Pa rt 50.
The three diesels were shipped to LILCO on the fol-lowing dates: diesel 101, February 27, 1976; diesel 102, March 27, 1976; diesel 103, May 14, 1976. Therefore, all three diesels were designed, fabricated, tested, and shipped prior to implementation of the required OA measures, in effect without full. regard for the potential
' impact of the identified discrepancies on the hardware.
Indeed, even at the time of the first audit in late 1975, DeLaval's design and procurement activities were nearly complete, and the fabrication of~ components at the DeLaval casting and manufacturing facility was well advanced. Thus, in many respects, the Stone and Webster audit l'argely represented an after-the-fact evaluation which resulted in-little or no effect on the Shoreham diesels. Rather prophetically, Mr. Bienduga, Stone and Webster Procurement Quality Control District Chief, observed in a January 29, 1976 memorandum which concerned the October 1975 audit: 15 - c
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Infeel'that DeLaval's response is too lit-
'tle too late as the audit was conducted to
- verify. compliance to the P.O. and approved O/ALprogram, not to upgrade their system for: future work. We should either get a TM-: ' positive response as to what actions are beingltaken now or we should stop the joh!
zFurthermore, there'were significant limitations in , the scopeLof the audit conducted on behalf of LILCO by
-Stone'and Webster. The 1975 audit, as well as the Lreaudits,, investigated DeLaval's compliance with only 11 i -:
..'o f - the y l 8 c criteria'of Appendix B: Criteria 4, 7, 9, 10
-~ and112:toi18.- The areas audited by Stone and Webster pri-
-marilyjinvolved procurementLand fabrication. -Critical-are'asiincluding design control (Criterion 3),9/ procedur-all control ~(Criterion 5), and-document control (Criterion 15)-wereJnotjaddressed in the Stone and Webster audit or reaudits. Thus, during the . entire course of DeLaval's design- and manufacture of the diesels ' for Shoreham, criti-
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cal / Appendix B criteria'were never audited, by LILCO or its crepresentative. Stone and Websters failure to audit the
'DeLaval" design activities, including-.the design verifica-
-tion-program,'isun significant. omission. Stone and
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9/ (We' note that the critical crankshaft failure of August
> :1983 resulted from design errors. See note 4 in this tes-timony.:
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y Webster, in ef fect, _ delegated responsibility for design OA activities to'DeLaval. Further, Stone and Webster failed
-to recognize early in the design and fabrication schedule
'the; potential problems that DeLaval might confront in sup-
-plying its first diesels for nuclear application. Indeed, Mr. Bienduga came to this-~ conclusion after the fact:
My personal feelings regarding this reaudit is that too much responsibility has been given a relatively young, inexperienced, quality engineering group. There seems to be passive acceptance-by the O/C Mgr. of excuses and not enough supervisory follow oup to get. things done.- Granted the LILCO order is their first 'nu-
. clear' contract _and there are many.' bugs' to he ironed out but that doesn't help our situation unless the O/C Mgr. is willing to take positive ste the ' bugs' out of'the system.10/ps to get In light of DeLavals' failure to meet adequate OA standards in other. areas, DeLaval's lack of nuclear expe-rience, .and Stone and Webster's knowledge of such failure and inexperience, this was a particularly deficient action by LILCO's contractor, which supports our belief that the problems with the DeLaval. diesels could possibly have been prevented by LILCO.
l10/ Stone.and Webster Interoffice memorandum, W. V. Bienduga, February 25, 1976.- 17 - t _ . _ . - . _ - , _ , _ . . _ . . - _ . __
8 0: What actions.should LILCO have taken after the knowledge it gained or.should have gained in the 1974-76 period? A: The serious deficiences in the OA implementation
~deficiences identified in 1974-76 should have alerted LILCO to.the need to carefully assess the adequacy of
'these diesels at an early date.
O: .Did LILCO commence such an early reassessment program? t-. A: No. LAs noted above,.LILCO did not start such a program until-Fall 1983.
.. Ch Between 1976_and the Fall of 1983 did LILCO acquire (or should it have acquired) further data to indicate the need
-for.an early revalidation or diesel replacement program, which, if implemented, would have eliminated.the need for LILCO to seek-the instant exemption?
'A Lyes. LILCO's experience with the DeLaval diesels commenc-ing in 1977 should have alerted LILCO at an early date'to potential OA problems, so that at-an early date LILCO
-should have taken steps to avoid the situation which'it
. presently confronts.
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Since late'1977, LILCO has discovered and repaired or
- sought' _to remedy numerous problems with the Shoreham die-nels. For example, 21 problems with the diesels that LILCO experienced prior to 1981 are set forth in a Januaryjl5, 19R1 letter from D.D. Terry of LILCO Start-Up to-Mr. Taylor. The-letter is appended as Attachment 3 hereto. These deficiencies also necessitated a number of Engineering and Design Coordination Reports (see Attach-ment 4 hereto) in order to attempt to achieve engineering resolution of'these problems, leading one LILCO employee to observe "we bought the low bidder."
'In addition, in 1983, Energy Consultants Incorporated conducted a retrospective assessment for the NRC of selected operational problems identified in LILCO Defi-ciency Reports, Repair / Rework Requests, and failure reports issued by LILCO and DeLaval. Energy Consultants'
- report,~ - issued prior to the . DeLaval cranksha ft failure, concluded:
A large number-and variety of problems that have been experienced can be attributed to vendor workmanship. These errors, in con-
-junction with the problems identified dur-ing audits of DeLaval's Quality Assurance
. Program faudits/reaudits conducted October 1975, February 1976, and June 1976), indi-cate a weakly implemented Quality Control Program.
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(Emphasis supplied). Energy Consultants also observed that: During the detailed review of _ various De fi-ciency. Reports, Failure Reports and Repair / Rework Requests, a significant
- number of problems or errors have been identified which seem to have occurred due to errors ~and incomplete or improperly com-pleted work by the manufacturer.11/
Examples'of specific problems with the DeLaval diesels that Energy Consultants concluded fell into this category are_ set forth in Attachment 1 of its report. Other documents also-reveal a broad pattern of
- problems with the diesels. Indeed, even LILCO now asserts that:
Prior to the crankshaft failure, LILCO E had experienced a number of occurrentas at-tributable to defectively designed or fab-ricated diesel generator components, including threc leaking cylinder heads, de-fective jacket water pumps, leaking fuel' oil 1 injection lines, inadequate turbocharger' thrust bearing lubrication, inadequate piston skirt to piston crown 11/ Energy-Consultants Incorporated, " Witness and Evaluation
.of Emergency Diesel Generator Testing at Shoreham Nuclear Power StationLfor Nuclear Regulatory Commission, Region I
--Staff,' Final Report'of NRC' Contract No. 05-82-249 Parameter Purchase Order No. NRC-IE-82/83, Task 38", July 12, 1983,' appended as Attachment 5.
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f 1% attachment, broken rocker arm shaft bolts fand ' cracked subcover assemblies. While
'these-occurrences were generally of the type experienced in-the-shakedown of large g
diesel engines, they appear, nonetheless, to be attributable to defective design or fabrication.12,/ ' In.our opinion, LILCO could and should have recognized far'before Fall 1933.that the DeLaval-diesels were probably not. reliable, and thus, should have taken steps at,an earlier time to remedy.the diesel problem. However, LILCO failed to do-so. Instead, it let the situ-
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ation deteriorate to the point of a catastrophic failure of the. machines,uand now seeks.special treatment-from~the
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NRC. LILCO's: failure to take timely early action to address the rooticauses of DeLaval failures is also reflected in
~
LILCO's failure to take heed of the significant NRC find-ings of deficiences in the DeLaval OA program. For exam-ple, the NRC Staff has observed .that "the number of minor problems experienced'hy the TDI machines in nuclear
- service appears to be abnormally high."13/ A summary of 12/
~~
Letter, E.M. Barrett of LILCO to Robert E. Smith, counsel for DeLaval,1 December 2, 1983, appended as Attachment 6.
-13/: Nuclear. Regulatory Commission Board Notification 83-160, October 21, 1983, page 1. Enclosures 2 and 4 to the Board (Footnote cont'd next page)
- 21 -
u_.
FE - , a.;
~
. . operating; problems experienced with DeLaval diesels, which
, "was compiled by,the NRC Staff, is appended to this testi-mony as' Attachment 8.14/. In addition, during its vendor cinspections in'1983, the-NRC' inspectors identitied "conditionsLwhichzimply that portions of=the DeLaval OA Program have not been. carried out in accordance with the.
provisions of-10 CFR 50,- Appendix B.a15/ Further, the NRC' vendor ~ inspection program previously
'h'a d identified problems in the-implementation of the DeLaval OA' program. Beginning in 1979 and continuing ^
through,1983,-the NRC conducted nine inspections at
~ DeLaval. Sixty-two instances of regulatory violations.or nonconformances were documented.15./ This-number of' (Footnote cont'd'from previous'page)
Notification identify a. number of problems that have occurred with.DeLaval diesels over the last three years. It-is' appended as Attachment 7.-
, J14/I DeLaval: Diesel Generator Operation Experience,. handout.
. prepared by the Nuclear' Regulatory-Commission at a meeting:
on DeLaval diesels held. by the Staff in Bethesda, Maryland on January 26, 1984. . Appended as Attachment"8.
, 115/
~~
Nuclear Regulatory Commission Board Notification 83-160,
~
Octoberf 21, 1983,~page12 (attached as Attachment 7). The detail's of the allegations'have notubeen revealed by the NRC to avoid. compromising the ongoing investigation of. DeLaval~ being conducted by tn'e -NRC's Of fice of Investiga-- tions. 16/clNuclearIRegulatory Commission Vendor Inspection Reports (October 14tto 17, 1980), issued January 22, 1981; 81-01, (Footnote. cont'd next'page)
. . s
?
L. m.
f.,
. problems'in.the DeLaval OA program, many of which remained uncorrected over three years a fter the completion of the
'Rhoreham diesels,_ further demonstrates that the DeLaval OA process was suspect and that'LILCO, far before Fall 1933, should ha've recognized the unreliability of the DeLaval diesels and taken steps to institute a comprehensive revalidation program or to replace them completely.
Attached to this testimony as Attachment 9 is a sum-
-mary of the'DeLaval inspection history prepared by.the NRC's Vender Inspection Branch. Tne-vendor inspection
-history was discussed by John Collins, Regional Adminis-trator for-Region IV of the Nuclear Regulatory Commission, att a January 26, 1984 meeting NRC Staff /DeLaval Owners'
-Group' meeting. Mr. Collins expressed serious reservations about the adequacy of _ both the DeLaval and utilitys ' QA/OC program, as follows :
As we indicated at the beginning, we have summarized in these slides the findings. But, more that's of interest. If you care-fully review the findings that were handed (Footnote cont'd from previous page) Lto 16, 1981), issued September 18, 1981; 82-01, (January 25 to 29, 1982), issued April 15, 1982; 82-02, (August 23 to 26, 1992), issued December 8, 1982; and 83-01, (July 11 to 15, 1983), issued October 3, 1983.
n-to.you that were documented in the handout to you, one thing it says to me, in my Lopinion, is that not only has there been oproblems at the manufacturing shop, but also,.in my opinion, calls into cuestion the adequacy of the vendor programs or surveillance programs that are being conducted by the utilities. Had some of
.these_been identified up front by utilities on-site inspection programs, or receiving inspection programs, or procurement pro-grams, I think they could have been identi-fied even sooner than now. So, it really calls into ouestion your own programs.ll7
. (Emphasis added ) . Similarly, Mr. William Foster of the NRC Sta f f stated recently that the number
~
and nature of violations and nonconformance at
. DeLaval indicated to him that the DeLaval OA System was " ineffective."M/
Or, LWhat is the_ significance in the context of this proceeding.of the NRC's findings concerning
- t DeLaval with respect to LILCO's responsibility for the diesel failures that leave required it to seek.an exemption?
17/- ; John Collins, " Transcript of Meeting on DeLavsl Diesel
. Generators," held at the Nuclear Regulatory Commission headquarters, Bethesda, Maryland, January 26, 1984, appended as Attachment 10.
18/' Deposition of William Foster, May 22, 1984, at 16. ' ^_
~
- , - 4
,en. ---
4
?
$A: :LILCO should have been aware of the NRC's sh -
", DeLaval inspection findings since the reports were publicly-available. LILCO should have read these NRC inspection reports and taken
; appropriate actions. This-is especially the case;regarding-LILCO since~the 1974-76 experi-ence-(discussed at3ve) had given bases for concern.- We have found little evidence, how-
/
ever, of any systematic response by LILCO man-agement to' determine the root cause(s) in the OA/OC program implementation which resulted in the ' numerous nonconformances -found at DeLaval by the NRC. This. failure-by LILCO further supports our belief that LILCO's need for an exemption is
-the result of its'own inappropriate actions or inaction.19/
' lj9 /- 'LILCO should also have been alerted to potential problems with the Shoreham diesels as a result of the pattern of deficiencies in DeLaval's production of other diesel
-engines for nuclear service, which resulted in numerous operational problems. These problems were generally reported by DeLaval in Part 21, Title 10 of the Code of Federal Regulations reports, or by the owners of the die-sels in Pa rt' ' 50. 55 (e) , ' Title 10 of the Code of Federal
. Regulations reports. Copies of such Part 21 reports were sent to LILCO by DeLaval.
i 0: LIs ' there any other basis for your opinion that
.LILCO's-need for an exemption results from
.LILCO's own inappropriate actions?
7L: Lyes. DeLaval diesel owners have documented serious operational problems in non-nuclear ap-plications similar to those experienced by nu-clear. users.- Thus, in addition to the problems LILCO itself experienced with the DeLaval die-
. sels-prior to 1983, if LILCO had looked, it would.have found much additional-evidence of the unsatisfactory design and manufacture of DeLaval diesels - similar to the' Shoreham diesels. In our
~
opinion, in view of the. history known to LILCO of OA . problems ' with DeLaval, LILCO, prior to 1983, 'should have tracked and responded to the significant' problems with DeLaval diesels in non-nuclear applications. This is especially the case since the lack of -operating experience - of DeLaval diesels in nuclear applications should have led .LITIO to inquire how DeLaval diesels were performing in non-nuclear applica-tions. l
For example, the DeLaval diesels supplied for the ship M.V. Columbia have experienced many conoonent failures including: o Cylinder heads - design and manufacturing defects
~
o Cylinder _ liner distortion and wear - due to block ~ distortion o Piston._ ring distortion and wear - due to block distortion o Cylinder blocks - distortion and cracking o Connecting rod bearings - design of articu-lated connecting rod assembly o Main bearings - premature wear, high load-ing
-o Camsha fts - premature wear 20/
Based on the' preceding, the authors of the M.V. c-Columbia evaluation concluded: rM]ajor moving components of the engine failed or required an inordinate amount of corrective maintenance at a significantly higher rate as compared to either DeLaval's recommended scheduled maintenance or other 20/ ' Seaworthy Engine Systems Report No. 124-01, Evaluation Of
,~~
The Operational And Maintenance History Of, And Recent Modifications To, The Main Engines In the M.V. Columbia, April, 1983. Other shipboard failures of the same nature experienced by the Pride of Texas ~are set forth in Attach-ment A to letter from C.C. Wei, Falcon Carriers, Inc. to C. Matthews, DeLaval, Re Pride of Texas Engine Problems,
.Tuly 22, 1982.
typical. diesel manufacturer's TBOs. The
. types of failures and number of failures of some of_the major components indicates design deficiencies in these components.
Two critical components which have been subject to failure, which are not typically expected to routinely fail, were the artic-ulated connecting rods and cylinder blocks.21/
'O: ' Why' do you . believe that LILCO's . failure to consider non-nuclear data concerning the-DeLaval diesels was inap-
=propriate?
LA: As noted above,Ethe lack of DeLaval diesels in nuclear ap-plications should have led LILCO to inquire regarding their performance in'non-nuclear service. Indeed, LILCO itself apparently considered non-nuclear applications of
' the ~ DeLaval diesels to be relevant to the use of the die-ssels at Shoreham.. For example, LILCO relied upon DeLaval's allegedly good non-nuclear experience in other.
aspects of this proceeding. In his affidavit attached to LILCO's Opposition to Suffolk County's Motion to Add an Emergency Diesel Generator Contention, May 16, 1983, Mr. i Youngling of LILCO testified:
'21/ Seaworthy Engine Systems' Report No. 124-01, Evaluation Of The Operational'And Maintenance History Of, And Recent Modifications To, The Main Engines In the M.V. Columbia, April, 1983.
A t L _ .:
("E . l ?- The^ vendor has advised LILCO that the basic
. diesel engine in the Shoreham diesel gener-ators'has been in production since the early 1950's. .There are. 97 diesel engines in this country that are essentially id entical or very similar to the Shoreham diesels.
(Emphasis added). Mr. Youngling later testified that: Some of the diesels that we have cited in our 97 are marine application diesels, others are stationary application for power production and some are nuclear applica-tions.22/
.If LILCO had carefully scrutinized available data, how-ever, it would have found actually that very serious problems were being experienced in non-nuclear DeLaval diesels.
In our opinion, a careful and timely look by LILCO at the non-nuclear-experience with DeLaval diesels would have caused LILCO to review the adequacy of the Shoreham die-sels well before their catastrophic failure in 1903. How-ever, 'there is no evidence prior to 1983 that LILCO man-agement sought to conduct such reviews, despite the fact ' ~
'that diesel operation was critical to the startup of 22/
Transcript of diesel proceeding, June 10, 1983 (" Hearing Transcript"), at 21,291.
l Shoreham and despite the evidence, that grew stronger through the years, and of which LILCO had both direct and , indirect knowledge,-that DeLaval's diesels were seriously deficient for nuclear application.
- O:- Does LILCO's purchase of alternate diesel generators, as stated. in the Application - for Exemption (p. 25), support i
'the requested exemption?
i A: No. LAt.the October 26,-1983 LILCO Board of Directors meeting, the LILCO Board ratified a contract with the Fairbanks Morse Engine Division of Colt Industries (" Colt") for three 4400 kilowatt diesels for Shoreham at a cost'of'S12.995 million. However, that action does not change our opinion about the-reasons LILCO should not be granted the' requested exemption.. Long before 1983, LILCO could,;indeed should, have recognized the~ extremely
' serious problem with the DeLaval diesels and have perhaps purchasedidiesels-from Colt. Indeed, LILCO could have 1
' selected the Colt diesels originally,'and'thus have
-avoided' altogether the problems with the DeLaval diesels and the need for an exemption.
Colt submitted a bid in 1974 for three 4,296 kilowatt units.- The Colt bid exceeded the DeLaval pre,>osal by only-0 - 30 - A
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s .- waRQf,i, ermined go V be-technically unacceptable by LILCO be - y% Qp - ^ ,ca,use'the kilovett.. rating was' deemed larger-than
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, Colt's' prior experience in
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s supplying' nuclear grade:diesets was given insufficient s .g s n ..
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y LCO's technical ep luation.. In our opinion , I '
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processes would have ihg'one.as smoothly with
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t; as they'might-have;with Colt, whichhad.extensiveexperi-
- h. . ' ence-in qualifying its diesels for nuclear application.
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[ }Qst,d "hNn this-sense, perhaps DeLaval was not the lowest quali-s' ' T- fled bidder. _ s "Os : What impact)have the diy'sel problems had on the 'date for . ( * . i the operation of Shoreham? t s t=
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.n t would have been able to proceed A t [sLILCO contends ~ that ;- >
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u 23 /. " Technic #loEvaluation, Dinsel Generator Sets - 9HI-89,'" t' April 5,'11974, attached tc letter from J.P.: Allen, Stone &
;Wpbster project enginear,,to H.C. Buckley, LILCO gN J ..yurchasi Agent,-Agri1}11, 1974.
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Th' , 5; 4 ( s:. Atomicf 0afety1 Licensing Board issued its Partial Initial
- v. ,
(( ,' :3 Decision on. September.21, 1983 had it not b'een for the
' problems encountered with the diesels. Therefore, it
' appears that'~the.DeLaval diesel problems are responsible
-forthe delays from September 21, 1983 until such time as
-Shoreham begins^1ow' power' operation, and constitute the reasonsfor LILCO's alleged need for an exemption. As (noted previously, however, LILCO had ample opportunity
- prior to Fall 1993 to take actions to head off the diesels obeingfin the~ critical path. LILCO failed to take
; advantage of ithese numerous opportunities.
IV. . CONCLUSIONS O- lWhat are your conclusions concerning'the selection, pro-curement,; and installation of Shoreham's ' diesel genera- ' tors?; A:= Our. investigation of these ' problems reveals that LILCO, L. directly or: through its ' contractor, Stone and Webster, s failed to act appropriately to assure that it acquired and 4 -- installed: emergency diesel generators suited for u'se at J Shoreham.- 8 1 32 - 1
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a- information ,that demonstrated deficiencies in the g L , _. ' - # y" '.' { DeLaga14yA, program as bell as numerous flaws in the
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o JLILCO impr'operly excluded full coasideration of the
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*_ C'6ther potential' diesel generator suppliers, specifi -
,i 4 f cally the Colt bid, and failed to properly evaluate
. :, ^
j Calt'snuclearibxpprience; N_0f l. n ,
.$ q' o/ LILQ Jrelied too heavily upon DeLaval to design and
,f, hu't,acturethediesels, and thus failed to assure 3 ; l .e, 9, - /that 3DeLaval and Stone and Webster carried out their
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- o. : LILCO failed to conduct a suitable design verifica-
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, tion of the DeLaval' diesels at an early date, and thus. failed to detect that the diesels may have sig-nificant ' deficiencies that prevent their approval for nuclear application.
'o - LILCO failed to ' adhere to , the NRC 's OA/OC require-ments and thus - failed to take the planned and system-Et atic actions .necessary to ' provide adequate confidence
- n s
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k with this position.' Rather, it is because of LILCO's insufficient actions since 1974 in the total diesel gener-ator' procurement and installation process described above that this delay has occurre1. The problems arose far in g advance of LILCO's late 1982 preoperational testing pro-r gram ' and' with~ prompt action could have been addressed at a far Learlier date, thus eliminating any possible need for
. the exemption application. Thus, we conclude that the ex-s ceptional circumstances claimed by LILCO do not exist, particularly since LILCO itself is largely responsible for the problems 1which have occurred, and thus no exemption is warranted.
c a y S . b S d 4 i OC _.35 _ r; E
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i i i. i ATTACHMENT 1 t. i k p. 1 f. L
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 Associates, 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 plant 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 groups. Performed extensive safety analysis for Swedish Energy Commissioa 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 Safety 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 presentations on radio and television.
. 1973 --1976 Manager, Performance Evaluation and Improvement, General Electric Company -
Nuclear Energy Division, San Jose, California
. Managed seventeen technical and seven clerice.1 personnel with responsibility for establishment and management of systems to monitor and m
T I measure Boiling Water Reactor equipment and system operational performance. Integrated General Electric re sources 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, California 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 reactors 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 over
$3,000,000 in 1972.
1966 - 1968 Manager, Complaint and Warranty Service, General Ele (tric Company - Nuclear , Energy Division, San Jose, California
' Managed group of six persons with the responsibility for customer contacts, planning and execution o' 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 Departmer.t, Los Angeles, California Supervised approximately eight field apresentatives with responsibility for General-Electric steam and gas turvine installation and maintenance
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 maint2aance 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, General Electric Company, Erie, Pennsylvania, and Schenectady, New York Training assignments in plant facilities design and in steam turbine testingjat 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. 1953 Engineering Training Program, General Electric Company, Evendale, Ohio
- Training assignment with Aircraft Gas Turbine Department.
EDUCATION & AFFILIATIONS: BSME - 1953,. South Dakota School of Mines and Technology, Rapid City, South Dakoca, Upper 1/4 of class. Professional Nuclear Engineer - California. Certificate No. 0973. Member - American Nuclear Society L _.
t
'Various Company Training Courses during career including Professional
. Business Mar.agement, 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: Born November 20, 1931, Miller, South Dakota. Married, three children 6'2", 190 lbs., health - excellent Honorable discharge from United States Army Hobbies: 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 Plantst 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 NED0-20222, January, 1974.
- 4. Improving Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November 1973, published in general Electric N3DO-20222, January, 1974.
- 5. Application of Plant Outage Experience to Tmprove Plant Performance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974.
i
- 6. Nuclear Valve Testing Cuts Cost, Time, Electrical World, October 15, 1974.
i- : Y_
m
- 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 tc 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 SpentLFuel Storage Considerations, March 10,.1977.
- 12. Testimony of D. G. Bridenbaugh before the New York State Public Service Commission Siting Board Hearings concerning_the Jamesport Nuclear Power Statien, 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: 'D,ecommissioning of Pressurized Water Reactors, Sundesert Nuclear Plant u.arings, June 9, 1977.
- 14. Testimony by D. G. Bridenbaugh before'the California State Energy
. . .Ah 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:py 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,1 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. L e
+
f
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- r
_18. Testimony by;D. G. Bridenbaugh before the Norwegian Commission on
' Nuclear Power, subject: Reactor Safety / Risk, October 26, 1977.
~19. Swedish Reactor Safety Study: Barseback Risk Assessrent, MHB-n
'~ Technical Associates, January, 1978. (Published by CEe~Swedish Department'of Industry as Document Ds1 1978:1)
'20. Testimony by D. G. Bridenbaugh before the Louisicna 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
.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, 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 Ger.arating Facilities, December 5,
[. 1978, Austin, T9xas.
- 25. Testimony by D. G. Bridenbaugh for the Commonwealth of Massachusetts, Department of- Public Utilities, Impact of Unresolved Safety Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost at the Proposed. Pilgrim-2 Nuclear Plant, June 8, 1979.
- 26. Improving the Safety of LWR Power blants, MHB Technical Associates, prepared for U.S. Dept. of Energy, Sandia Laboratories, September 28, 1979.
, l27. BWR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), October, 1979.
- 28. Uncertainty in Nuclear Risk Assessment Methodology. MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), January 1980.
y -r+v,,-
U' 1 I
'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 Energy Commission, February 11, 1980.
.30. Italian Reactor Safety Study: Caorso Risk Assessment, MHB Technical Associates,.for Friends of the Earth, Italy, March, 1980.
13 1 . Decontamination of Krypton-85 from Three Mile Island Nuclear Plant, _H. Kendall, R.. Pollard, & D. G. Bridenbaugh, et al, The Union of Concerned: Scientists, deliverc.d to'the Governor of Pennsylvania, May p ,
,15,il980.
b
-32. LTestimony by D. G.-Bridenbaugh before the New Jersey Board of Public
-Utilities, on behalf of New Jersey Public Advocate's Office, Division I? ,
of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, August, , 1980. I 33. Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, for Minnesota Pollution Control Agency, September, 1980.
- . -34. Position Stetement, Proposed Rulemaking on the Storage and Disposal of Nuclear Wtstt,' Joint Cross-Statement of Position of the New England Coalition on Nuclear Pollution and the Natural Resources Defense Ccuncil, September, 1980.
- 35. ' Testimony by D. G. Bridenbaugh and G. C. Minor, before - the New York
-F State Public Service _ Commission, In the Matter of Long Island Lighting Company Temporary Rate Case, prepared-for.the Shoreham Opponents
-Coalition, September 22, 1980, Shoreham Nuc' ear Plant Construction
-Schedule.
, 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.
~
' 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 i
' , ' Public Advocate,, Division of Rate Counsel, Oyster Creek 1980 Re _'oeling (Outage Investigation, February 1981,
- 38. " Economic Assessment: . Ownership Interest in Palo Verde Nuclear Station, MHB Technical Associates, for the City of Riverside, a 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 Toledo Edison Company and Related Matters, subject: Davis-Besse Nuclear Power Station 1980-81 Outage Review, November 1981.
- 41. Systems Interaction and Single Failure Criterion, Phase 2 Report, MHB Technical Associates for the Swedish Nuclear Power Inspectorate (SKI),
January, 1982. . ?k '4 2 . 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 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, 1982.
- 47. Testimony of D.'G. Bridenbaugh and G. C. Minor before the Atomic Safety and Licensing Board, on behalf of Suffelk County, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1,-regarding Suffolk County Contention 11, Passive Mechanical 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.
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- 49. 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 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 1
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. Br'idenbaugh before the Illinois Commerce
. Commission, on behalf of the Illinois Attorney General's Office, 1 Expected Lifetimes and Performance of Nuclear Power Plants, June 18, 1982.
- 52. ' Testimony of D. G. Bridenbaugh and R. B.' Hubbard on behalf of the Ohio Consumers Counsel,' before 'the Public Utilities Commission of Ohio, regardingl 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 c5 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 1,.Re: Pennsylvania Power and. Light, Maren 18,
- 1983.
DC 56. _, Surrebuttal Testimony of D. G. Bridenbaugh before the Pennsylvania MP ' 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.- , _ _ f57. ' 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
~
l l
, Counsel, October 13, 1983 a
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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, THE 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, Division 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.
l l i
-10 i
w E-W ATTACHMENT 2 k, -
PROFESSIONAL QUALIFICATIONS OF RICHARD B. HUBBARD RICKARD B. HUBBARD MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 EXPERIENCE: 9/76 - PRESENT Vice-President - MHB Technical Associates, San Jose, California. Founder, and Vice-President of technical consulting firm. Specialists in independent energy assessments for government agencies, particularly
. technical and economic evaluation of nuclear power facilities. Consultant in this capacity to California, Massachusetts, Oklahoma and Illinois Attorney Generals, Minnesota Pollution Control Agency, German Ministry for Research and Technology, Governor of California, Swedish Energy Commission, Swedish Nuclear Inspectorate, Suffolk County, Ohio Consumer's Counsel, New Jersey Public Advocate, and the U._S. Department of Energy. Also provided studies and testimony for various public interest groups including the Center for Law in the Public Interest, los Angeles; Public Law Utility Group, Baton Rouge, Louisiana; Friends of the Earth (F0E), Italy; and the Union of Concerned Scientists, Cambridge, Massachusetts. Provided testimony to the U.S. Senate / House Joint Committee on Atomic Energy, the
~
U.S.' House Committee on Interior and Insular Affairs, the California Assembly, Land Use, and Energy Committee, the Advisory Committee on Reactor Safeguards,_ and the Atomic Safety and Licensing Baard. Performed comprehensive risk analysis of the accident probabilities and consequences at~the Barseback Nuclear Plant for the Swedish Energy Commission and edited, as well as contributed to, the Union of Concerned Scientist's technical review of the NRC's-Reactor Safety Study (WASH-1400). 2/76 - 9/76 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 presentations on radio and television. l L __ _
n 3 5/75 - 1/76 Manager - Quality Assurance Section, Nuclear Energy Control and Instrumentation Department, General Electric Company, San Jose, California. Report to the Department General Manager. Develop and implement quality plans, programs, methods, and equipment which assure that products produced by the Department meet quality requirements as defined in NRC regulation 10 CFR '50, Appendix B, ASME Boiler and Pressure Vessel Code, customer contracts, and GE Corporate policies and procedures. Product areas include radiation sensors, reactor vessel internals, fuel handling and servicing tools, nuclear plant control and protection instrumentetion systems, and nuclear steam supply and Balance of Plant control room panels. Responsible for approximately 45 exempt personnel, 22 non-exempt personnel, and 129 hourly personnel with an expense budget of nearly 4 million dollars and equipment investment budget of approximately 1.2 million dollars. 11/71 - 5/75 Manager - Quality Assurance Subsection, Manufacturing Section of Atomic Power Equipment Department, General Electric Company, San Jose, California. Report to the Manager of Manufacturing. Same functional and product responsibilities as in Engagement #1, except at a lower organizational report level. Developed a quality system which received NRC certification in 1975. The system was also successfully surveyed for ASME "N" and "NPT" symbol' authorization'in 1972 and 1975, plus ASME "U" and "S" symbol authorizations in 1975. Responsible for from 23 to 39 exempt personnel, 7 to 14 non-exempt personnel, and 53 to 97 hourly personnel.
'3/70 - 11/71 Manager - Application Engineering Subsection, Nuclear Instrumentation Department, General Electric Company, San Jose, California.
Responsible for the post order technical interface with architect engineers and power plant owners to define and schedule the instrumentation and control systems for the Nuclear Steam Supply and Balance of Plant portion of nuclear power generating stations. Responsibilities included preparation of the plant instrument list with approximate location, review of interface drawings to define functional design requirements, and release of functional requirements for detailed equipment designs. Personnel supervised included 17 engineers and 5 non-exempt personnel. 12/69 - 3/70 Chairman - Equipment Room Task Force, Nuclear Instrumentation Department, General Electric Company,-San Jose, California. Responsible for a special task force reporting to the Department General Manager to define methods to improve the quality and reduce the i
installation time and cost of nuclear power plant control rooms. Study resulted'in the conception of a factory-fabricated control room consisting of signal conditioning and operator control panels mounted on modular floor sections which are completely assembled in the factory and thoroughly tested for proper operation of interacting devices. Personnel supervised included 10 exempt personnel. I' 12/65 - 12/69~ Manager - Proposal' Engineering Subsection, Nuclear Instrumentation Department, General Electric Company, San Jose, California. Responsible for the application of instrumentation systems for nuclear power reactors during the proposal and pre-order period. Responsible for technical. review of bid ' specifications, preparation of technical bid clarifications and exceptions, definition of material list for cost estimating, and the "as sold" review of contracts prior to turnover to Application Engineering. Personnel supervised varied from 2 to 9 engineers.
'8/64 - 12/65 Sales Engineer, Nuclear Electronics Business Section of Atomic Power Equipment Department, General Electric Company, San Jose, California.
Responsible for the bid review, contract negotation, and sale of instrumentation systems and components for nuclear power plants, test reactors, and radiation hot cells. Also responsible for industrial sales of radiation sensing systems for measurement of chemical properties, level, and density. 10/61 - 8/64 Application Engineer, Low Voltage Switchgaar Department, General Electric Company, Philadelphia, Pennsylvania i Responsible for the application and design of advanced diode and silicon-controlled rectifier (SCR) constant voltage DC power systems and variable voltage DC power systems for industrial applications. Designed, fcilowed manufacturing and personally tested an advanced SCR power supply l for product introduction at the Iron and Steel Show. Project Engineer.for a DC power system for an aluminum pot line provided to Anaconda beginning at the 161KV switchyard and encompassing all the equipment to conve t the power to 700 volts DC at 160,000 amperes. 9/60 --10/61 GE Rotational Training Program Four 3-month assignments on the GE Rotational Training Program for college technical graduates as follows: i
- a. Installation and Service Eng. - Detroit, Michigan Installation and startup testing of the world's largest automated hot strip steel mill,
- b. ~ Tester -- Industry Control - Roanoke, Virginia Factory-testing of control panels for control of steel, paper, pulp, and utility mills and power plants,
- c. Engineer --Light Military Electronics - Johnson City, New York Design of ground support equipment for testing the auto pilots on the F-105.
- d. Sales Engineer - Morrison, Illinois Sales of appliance controls including range timers and refrigerator cold controls.
EDUCATION:
. Bachelor of Science Electrical Engineering, University of Arizona, 1960.
Master.of Business Administration, University of Santa Clara, 1969. PROFESSIONAL AFFILIATION:
' Registered Quality Engineer, License No. QU805, State of California.
Member of Subcommittee 8 of the Nuclear Power Engineering Committee of the IEEE Power Engineering Society responsible for the preparation and revision of the following national Q.A. Standards:
;a. IEEE 498 (ANSI N45.2.16): Requirements for the Calibration and Control of Measuring and Test Equipment used in the Construction and Maintenance of Nuclear Power Generating Stations.
- b. IEEE 336 ( ANSI N45.2.4): Installation, Inspection, and Testing Requirements for Class lE Instrumentation and Electric Equipment at Nuclear Power Generating Stations.
- c. IEEE 467 : Quality Assurance Program Requirements for the Design and Manufacture of Class 1E Instrumentation and Electric Equipment for Nuclear Power Generating Stations.
I am currently a member of the IEEE Committee which is preparing a standard
-relating to t? 2 selection and utilization of replacement parts for Class lE equipment during the construction and operation phase.
E: ._
iPUBLICATIONS AND TESTIMONY:
- 1. In-Core Syst'em Provides Continuous Flux Map of Reactor Cores 1
R. B. Hubbard and'C.-E. Foreman, Power, November, 1967. 2' Quality Assurance: Providing It, Proving It, R. B. Hubbard, Power, May, 1972.
.3. ; Testimony of R.-B. Hubbard, D. G.' Bridenbaugh, and G. C. Minor before the United States Congress, Joint Committee on Automic Energy, February 18, 1976, Washington, D.C. (Published by the Union of 1 Concerned Scientists, Cambridge, Massachusetts.) Excerpts from testimony published.in Quote Without Comment, Chemtech, May, 1976.
- 4. Testimony of R. B. Hubbard, D. G. Bridenbaugh,.and G. C. Minor to the
. California State Assembly Committee on Resources, Land Use, and Energy, Sacramento, California, March 8, 1976.
- 5. - Testimony of R. B. Hubbard and G.' C. Minor before California State Senate Committee on Public Utilities, Transit, and Energy, Sacramento, 1 California, March 23, 1976.
6I. - Testimony of R. B. Hubbard 'and G. C. Minor, Judicial Hearings
- Regarding Grafenrheinfeld Nuclear ' Plant, March 16 & 17, 1977, Wurzburg, Germany.
4 J7. Testimony of R. B. Hubbard to United States House of Representatives, Subcommittee on Energy and the Environment, June 30, 1977, Washington, D.C., entitled, Effectiveness of NRC Regulations - Modifications to Diablo Canyon Nuclear Units.
- 8. . Testimony of R. B. Habbard to the A?visory Committee on Reactor L Safeguards August-12, 1977, Washington,~D.C., Risk Uncertainty Due to Deficiencies'in Diablo Canyon Quality Assurance Program and Failure to Implement Current NRC Practices.
9. The Risks of Nuclear Power Reactorsi A Review of the NRC Reactor Safety Study WASH-1400, Kendall, et. al., edited by R.,B. Huobard and
- G. C. -Minor for the Union of Concerned Scientists, August, 1977.
- 10. .Swedish Reactor Safety Study: Barseback Risk Assessment, NHB Technical Associates, January 1978 (Published by Swedish Department of
, Industry as Document DSI (1978:1).
11.. ' Testimony of R. B. Hubbard before the Energy Facility Siting Counsil, March 31, 1978, in.the matter of._ Pebble Springs Nuclear Power Plant, l-Risk Assessment: Pebble Springs Nuclear-Plant, Portland, Oregon. l- '
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- 12. : Presentation by R. B. Hubbard before the Federal Ministry for Research and Technology (BMFT), August 31 and September 1, 1978, Meeting on Reactor Safety Research, Risk Analysis. Bonn, Germany.
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- 13. Testimony by R. B. Hubbard, D. G. Bridenbaugh, and G. C. Minor before the Atomic Safety and Licensing Board, September 25, 1978, in the
. matter of the Black Fox Nuclear Power Station Construction Permit
- hearings, Tulsa, Oklahoma.
- 14. Testimony of R. B. Hubbard before the Atomic Safety and Licensing Board, November 17, 1978, in the matter of Diablo Canyon Nuclear Power Plant Operating License Hearings, Operating Basis Earthquake and (Seismic Reanalysis of Structures,-Systems, and Components, Avila Beach, California.
- 15. Testimony of-R. B. Hubbard and D.' G. Bridenbaugh before the Louisiana Public' Service Commission, November 19, 1978, Nuclear Plant and Power
, ; Generation Costs, Baton Rouge, Louisiana.
-16. Testimony.of'R. B. Hubbard before the California Legislature, Subcommittee-on Energy, Los Angeles, April 12, 1979.
I ~
- 17. Testimony of R.~ B. Hubbard and G. C. Minor before the Federal Trade Commission, on: behalf of the Union of Concerned Scientists, Standards t
; -m and Certification Proposed Rule 16 CFR Part 457, May 18, 1979.
_ 18. : ALO-62, Improving the Safety of LWR Power Plants, MHB . Technical Associates, prepared for U.S. Department of Energy, Sandia National Laboratories,-September, 1979, available from NTIS.
- 19. ~_ Testimony by R.' B. Hubbard before the-Arizona State Legislature, Special Interim House _ Committee on Atomic Energy, Overview of Nuclear Safety, _ Phoenix, AZ, September 20, 1979.
- 20. .' "TheLRole of the Technical Consultant",. Practising Law Institute F program on." Nuclear Litigation", New York City and Chicago, November, 1979. Available from PLI, New York City.
- 21. ~ Uncertainty in Nuclear Risk Assessment Methodology, MHB Technical Associates, March, 1980, prepared for and available from Swedish Nuclear Power. Inspectorate, Stockholm, Sweden.
. 22. Italian Reactor-Safety Study: Caorso Risk Assessment, MHB Technical Associates, March, 1980, prepared for and available from Friends of
, the Earth, Rome, Italy. -
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- 23. Development of Study Plans: Safety Assessment of Monticello and Prairie Island Nuclear Stations, MHB Technical Associates, August, 1980, prepared for_and available from the Minnesota Pollution Control Agency.
- 24. AffidaviL of Richard B. Hubbard and Gregory C. Minor before the Illinois Commerce Commission, In the Matter of an Investigation of the
-Plant Construction Program of the Commonwealth Edison Company, prepared for-the League of Women Voters of Rockford, Illinois, November 12, 1980, ICC Case No. 78-0646.
- 25. Systems Interaction and Single Failure Criterion, MHB Technical Associates, January, 1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
- 26. ' Summary of Emergency Response Planning Criteria for Regional and Local Authorities Near Nuclear Electric Generating Stations, MHB Technical Associates, June, 1981, prepared for and available from Friends of the Earth,' Rome, Italy.
- 27. Economic Assessment: Ownership Interest In Palo Verde Nuclear Station, September 11, 1981, prepared for and available from the City of Riverside, California.
- 28. Systems Interactica and Single Failure Criterion: Phase II report, MHB Technical associates, December, 1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
-29. Testimony of Richard Hubbard and Gregory Minor on Emergency Response Planning, Diablo Canyon Operating License hearings before ASLB, January. 11, 1982.
- 30. Statement of Richard Hubbard before the U.S. House Subcommittee on Energy and Environment concerning QA program breakdowns, November 19, 1981.
- 31. Testimony of Richard Hubbard on Quality Assurance, South Texas Operating License hearing before ASLB, prefiled June, 1981.
- 32. Presentation of Richard Hubbard for Governor Edmund G. Brown, jr.
concerning PG6E's Proposed Seismic Design Reverification Program, Diablo Canyon Nuclear Power Plant, February 1982.
- 33. Testimonyo"f R. B. Hubbard, G. C. Minor, M. W. Goldsmith, S. J.
Harwood en 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 Contention 7B, Safety Classification and Systems Interaction, April 13, 1982.
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_. . 34 . Testimony of R. B. Hubbard and D. G. Bridenbaugh, 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.
- 35. Te'stimony of'R..B. Hubbard 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 27 and SOC Contention 3, Post-Accident Monitoring, May 25, 1982.
136. Presentation of R..B. Hubbard for Governor Edmund G. Brown, Jr. concerning-Diablo Canyon Reverification Program, Diablo Canyon Nuclear PowerfPlant, September,~ 1982.
- 37. Testimony of R.~B. Hubbard on behalf of Suffolk County,.before the J
Atomic Safety and Licensing Board, in the matter of Long Island Lighting-Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contentions- 12, 13, 14, and 15, Quality Assurance / Quality Control, June 29, 1982.
- 38. Presentatio'n of Richard B.'Hubbard on Behalf of the State of California, Before the NRC Commissioners, Proposed Phase II Diablo Canyon' Reverification Program.(IDVP), November 10, 1982.
39.. L Testimony ~of[R.:B.'Hubbadd and Dr. Francisco J. Samaniego on behalf of ' Ot
.Suffolk County,' Before the Atomic Safety and Licensing Board, in.the matter' of- Long Island Lighting Companyi Shoreham Nuclear Power-L Station", Unit 1, regarding Torrey Pines Technology's' Inspection.of Shoreham Nuclear. Power Station, December. 21, 1982.
- 40. Supplemental testimony.of Gi C. Minor, R. B. Hubbard, and M.'W.
" GoldsmithEon behalf of Suffolk County,=before the Atomic Safety _and Licensing-Board, in the matter of Long Island Lighting' Company,
' Shoreham Nuclea'r Power Station,' Unit 1, regarding Suffolk County Contention 7B, Safety Classification and: Systems Interaction, March
-23, 1983.
- 41. . Supplemental Affidavit of R. B. Hubbard before the Atomic Safety'and
' Licensing-Appeal' Board Concerning Breakdowns in the Diablo Canyon.
' Quality Assurance Program, March 29, 1983.
- 42. Declaration of R. B. 'Hubbard before the Atomic Safety and Licensing
- Appeal: Board, Concerning Breakdowns in ' Construction Quality Assurance -
, at Diablo-Canyon, May.6, 1983.
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- 43. Presentation by R. B. Hubbard on behalf of Suffolk County to Cuomo
-Commission regarding Quality Assurance / Quality Control (QA/QC).
- 44. Testimony of R. B. Hubbard on Behalf of the State of California, Before the Atomic Safety and Licensing Appeal Board, in the matter of Pacific Gas and Electric Co., Regarding Design Quality Assurance, October,1983.
- 45. Testimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard and G. C.
Miror 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.
- 46. Status Raport, WJ Zimmer Plant, Assessment of Options, MHB Technical Associates, prepared for The Ohio Office of the Consumer's Counsel, February 23, 1984.
O I
r b r o I~ ATTACIIMENT 3 d% a i e k i I ',- _r I
~
I ul_u
[ / L " 3 OMj , a S 27 - 2/+.1 Oi0 i l January 15, 1981 l J.E. Taylor l Emergency Diesel Generator 102 Problems Encountered To Date Shoreham Nuclear Power Station - Unit No. 1 ! W.O. 44430/48923 i ( The attached report, prepared by T. Brown, J. Higgins and W. Cook accurately state the problems we have had to date. l An attempt to resolve many of the items was tried on December 18, 1980 when Startup arranged a meeting between ourselves, i S&W and Delaval. Regretfully, Delaval could not attend and no i real progress on oroblem solutions were made. Another meeting is scheduled for January 20, 1981 at Shoreham
- and hopefully resolution to many problems will be achieved.
j Many of the problems encountered by Startup to date have been the result of the " Skid Mounted Equipment", as with this type, the Construction organization has very minimal involvement other than " hooking up" to it. Along these lines, alignment deficiencies have been identified, storage problems have been corrected etc., all of which adds to Startup's scope of work as related to placing the equipment into service. A rescheduling effort of the Diesel generators must be conducted ' due to the recent Proposed Site policy to primarily support the Integrated Flush. At the present time, we can not project a preop start date due to many unresolved problems and no projected turnover date for Engines 101 and 103.
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D.D. Ter COMP-
! Lead Sta up Engineer gig C/C 00c l
i DDT:be l cc: T. Brown J. Higgins W. Cook L.W. Lewin W.M. Matejek i SR2-R43.010 t i I g
~- - _ _ _ _ _ _ _ ,
! li* . l l PROBLEM REPORT B i R43-* EMERGENCY DIESEL GENERATORS I 1- Procedure that had been JTG approved for subsystem flushes were not adequate. Specifically, the lube oil flush did not provide sufficient flow to clean the system. (this test procedure used B&A pump (40GPM.) which has a normal flow of about 250GPM. Also, the JW system flush procedurs
- uses the J.W. heater circulating pump (50GPM) for a sys-l tem with a nomal flow of 800 GPM. This procedure will i
be revised to incorporate a temporary flush pump. l 2- Excessive amounts of time were required to review component i lists since (a) initial list missed many items (b) iseme-tries are continually changing resulting in added and/or i deleted' sections, and (c) hanger listings change as isos are revised and the des'ignation changes (E&DCR F 29376) . Changes in component lists are no longer to be reviewed -
.[ only marked noted by test engineer.
l 3- Excessive amounts df time was required to review punchlist items. This was compounded by (a) reorganization of lists by renumbering all items, (b) excessive number of items, i (c) failure to perform verification of completion by turnover and (d) non-infomative responsiblity assignment. l l l t l I
- l I
, -c ,- t 4 \ \ g p, I _ ',t ' g
~
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.s y, ,
y N Responsibility is not discussed with the individual N resultU.ng frequently in the wrong discipline being ! s 3 . assigned, the individual being unaware of his responsi-l j bilsty, and the wrong completion code being assigned. 4 l The issuing of the consplete list each month instead i of a list of changes results in an impossible review c task. l l 4- Excessive amounts of time are required for review of i preliminaries. New preliminary release packages are F submitted for review with little or no change in the t-punchlists. Meetings are called to discuss package 1 updates with the only change being requests for further concessions on number of items required for turnover. R43A has had six preliminaries and the punchlist is still
~
some 46 pages long. Constru'6ti%n's'Eaths f 6F"fil'ehfiias~ poor-s-weArecei-ved i 5-a minimum of requested storage history information. Final engine alignment was not performed. There was no record of foundation bolt torquing. Megger readings of generator stator were not up to date. Megger reeding of generator field and bearing pillow block were non-existant, i 5
l I 6- manerous detrgn_cac cdQtruction errors necessitatad ini-w .w . . _ tiation of E&DCR's ( 65 to date. This has resulted in i L an exorbitant amount of time being expended reviewing drawings and documents. Many of the original problem solutions were incorrect which resulted in rewriting the E&DCR or calling SEO to request the next issue. We have attempted to get the drawings updated to reflect the system as it was designed and to get the drawings that the diesels were built to, but usually we are requested to mark up prints reflecting as built conditions. Problem soluticns are at a standstill at present, only one has been answered since the end of October - nineteen are unanswered. 7- . Numerous repair-reworks (.38) have been written because
-- 3 of many incomplete _or defective dtems. Some of these are
--_. s a result of E&DCR's,some are a Ys5' ult.cf.. poor.. factory 7
assembly
- practices, some are a result of a forced turnover with incomplete / deficient components, and some are a re-sult'of poor construction practices. A great amount of time was expended in obtaining documentations 2cg.reworA_
. ~ ~ ~ ~
of. factory wiring. This has also been expended on attempts to expedite parts and tools for reworks. l l l l-l l I' .- - - . _ , _ _ . - - _ - . .
. ... ._m-I' e- Extra time has been expended because of numerous techni-cian changes with no overlap. This has resulted in seem rework, additional time locating equipment, and -
additional time locating documents. 9- Many hours have been expended attempting to get informa-
- tion for CsIo work (especially the tach-relay, the fuel oi3 Booster Pump D.C. motor loss of field reley) with l_
incomplete results. Many hours have been expended attempting to set up for testing D.C. Circuit breakers since there is no regulated DC power supply of 30 amp capacity on site. i , Pdor~rtorage. conditions..and2w"o~rtarea cohyoh-duti g
~
p c_onstruction~~phanes had to be compensated by cleaning of the 102 generator by Startup support. 11- Poor design of panel cable support and poor housekeeping during construction resulted in a prolonged cleaning effort to achieve error free operation of relays. 12- original schedules did not allow time for rewritting procedures, reperforming C&Io work because of design L changes, performing design and construction review. 13- original C&Io schedule by previous test engineer allowed six weeks. A' recalculation including all equipment with the same allowed time for devices, indicates that fifteen weeks should be allowed, l: .- .. - , .u_.._._. . _ . _ _ . . . . _ _ _ . _ _ . _ . _ . . _ _ _ . , _ _ . _ _ _ _ _ _ _ . _ _ . . _ _ _ _ _ . _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ . _ _ _
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14- Modification of diesel generators to upgrade design i are being incorporated. This was not allowed for this l in the assigned scheduls. , 15- Additional time and manpower was required to clean crank cases of diesel since preservative of wrong type was sus-
-pected to have been used=on engine during storage.
l 16- Additional Test Engineer time was expended clearing construction red tags after system release. 17- Failure to be able to control access to the Diesel room because construction activities were in progress slowed Startup activities. Construction work on rewiring MCC, installing scaffolds (for X60 actuators, service water line walk, and conduit resupport), and reworks assigned [ to construction. Temporary doors were unlocked, knocked l down and holes were cut in them. 18- Power feed (120VAC) Repair / Rework (R35-6) pravanted com-plate testing of accessories. 19- ASME piping was not turned over at original "B" release. There has been confusion in this area concerning who I owns which components. We are still unable to use Startup Suppcrt to break flanges on these systems - this results
-in poor control of activities by Startup.
20- Lack of personnel continuity has impacted progress - three turnover engineers have been responsible for R43 l since May 1980. 21- Many hours have been spent listing problems with design, drawings, construction, and documentation. Many hours
- have been ' spent attending meetings - the only result thus far has been requests for mors paperwork, (lists & copies j
of specific E&DCR's) and more meetings. We need to have l the diesel generators Placed on a higher priority if , we are to meet a date required to support other plant activities. i O 1 O a l l l t
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':any E5DCRs have been written for the R43 Sys en, diesel generators, vit: ::s- of these E1 DORS being initiated by L1_00 5: art-L'p.
2 The d_esel genera::r specifica:ien 5.1-089 is ainly a perfor=ance specifica:ict., i.e. design output parameters, with detailed design f :he s:s:e: :o be supplied by *,eisval. The specification, however, l
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does require certain specific de: ails such as alar =s and shutdown ! ini:ia: en signals. Wi:n a pt:f or=ance specifi:a-icn as a basis s S&W
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a caj rity e.~ vhich are details re:uired to che:k Out =anual furnished I subsys:ers because the installation and main:enan:5 j by Delaval doesn': provide enough infcr:a:1en on se: points and design , para =e:ers :o check various instru=entation. . here are siso cases where addi-icnal details en S&W drawings vould have helpec :o eliminate construe: ion and star:-up problems. I perspective, i
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5:ar:-up is also reviewing things in general vi:h a different than : sese:i=es reviewing -he main:ainability to a such greater exten: . nw has. In locking back through some of the ELDCRs ve see =any requests for addi:ional infor:c: ion, se=etime.s not the appropria:e vehicle for , f reques-ing the inf or:ation, bu: a =eans by which a do: mented answer is required. There are cases where venders.' drawings did no ta :t the and SSWequipmen drawings. thus resultin; in incensis:encier be:veen vend:: nspe::ica ::uld have unc:vered this. We de not an:icipate si:11a problems vi:h securi:y, except probab,_y
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' iiii!1 SEVENTH :n i Ht=t= 1 PITTSBLEGH, F%.M222-34Er7 4121434-5200 JAK-ENG-83-181 ,
July 12, 1983 Mr. E. B. McCabe U.'S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia PA 19406 ,
SUBJECT:
WITNESS AND EVALUATION OF EMERGENCY DIESEL GENERATOR TESTING AT SHOREHAM NUCLEAR POWER STATION FOR NUCLEAR REGULATORY COMMISSION, REGION I STAFF. FINAL REPORT OF NRC CONTRACT NO. 05-82-249 PARAMETER PURCHASE ORDER NO. NRC-IE-82/83 TASK 38
Dear.Mr. McCabe:
Enclosed are five (5) copies of the final report of the Evaluation and Witnessing of Emergency Diesel Generator Tesring Problems at Shoreham Nuclear Power Station which was performed at Shoreham, New York by Mr. Gailard Kunkle and the Enargy Consultants. Inc. staff in accordance with the riference contract. The final report incorporates the NRC comments on the preliminary report provided to Mr. G. Kunkle at the meeting in Region I on June 29, 1983.
. The preliminary report was submitted to you previously by JAK-ENG-83-161 dated June 17, 1983.
If you shculd have 'any questions or consnants, please contact me. Sincerely, ENERGY CONSULTANTS, INC. John A. ye i Manager . I Design and Consulting l Engineering Department RJA/cv Enclosures cc: Jim Riggins - U. S. Nuclear Regulatory Commission Richard A. Lofy - Parameter Incorporated e e
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kl.'* P '-=7'#l % TiWit A W i@i % Nhh - FINAL REPORT TO U. S. NUCLEAR REGULATORY COMMISSION REGION I l FLR TEST REVIEW, DATA ANALYSIS AND REVIEW OF EMERGENCY DIESEL GENERATOR OPERATIONAL / RELIABILITY PROBLEMS AT SHOREHAM NUCLEAR POWER STATION, UNIT I, SHOREHAM, NEW YORK NRC CONTRACT NO. 05-82-249 PARAMETER CONTRACT NO. NRC-IE-82/83, TASK 38 FROM APRIL 25, 1983 TO MAY 19, 1983 PRESENTED ON JULY 12, 1983 BY DESIGN AND CONSULTING ENGINEERING DEPARTMENT ENERGY CONSULTANTS, INC. 121 SEVENTH STREET PITTSEURGH, PENNSYLVANIA 15222-3487 (412) 434-5230 PREPARED SY . .
%./2l4///M iV REVIEWED EY . O. N/A//d iV
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TABLE OF CONTENTS
- Section- Title a Page, i
I. Introduction'. . . . . .'. . . . . . . . . . . . . . . 1 A. Summary. . . ... . . . . . . . . . . . . . . . . . 1 B. ^ Equipment Idantification . . . . . . . . . . . . . 3 C. Background . . . . . . . . . . . . . . . . . . . . 3 i D. Inspection Objectives. . . . . . . . . . . . . . . 4
'E. Persons Contacted. . . . . . . . . . . . . . . . . 4 II Testing. . . . . . . . . . . . . . . . . . . . . . . . 6 i:
III Corrective / Preventive Maintenance and . Maintenance Records. . . . . . . . . . . . . . . . . . 10 IV: Visual Inspections of Diesel Generators. . . . . . . . 14 Y. Review of Component Problems / Failures. . . . . . . . . 15 A. Engine Head Cracks . . . . . . . . . . . . . . . . 15 i B.. Turbocharger Failure . . . . . . . . . . . . . . . 16-I .
- C. Engine Block Casting Indications . . . . . . . . . 17 D. General Review of Problems . . . . . . . . . . . . 18 Y -General Recommendations. . . . . . . . . . . . . . . . 22 l
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i g EVALUATION OF DIESEL ENGINE PROBLEMS AND TESTING AT SHORMAM. NEW YORK . I. INTRODUCTION - A. Sununarv: An . in depth assessment of selected operational problems was conducted which included arsas such as corrective maintenance, preventive maintenance and
- component fc.11ure.
This assessment included detailed reviews of selected problems _ identified in Long Island Lighting Company (LILCO) Deficiency
. Reports, Repair / Rework Requests issued by the Start-up ' Group and failure reports issued by LILCO, Delaval and other vendors. In addition, observation of maintenance activities as well as a physical inspection of each emergency diesel generator unit was conducted during both standby and, when possible. -
running conditions. During' the review of each item, an attempt was made to determine the following:~ (a) Was the work accomplished in accordance with approved proce.dures? (b) Were properly calibrated tools (if applicable) used during I-maintenance?
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(c) . Were measurements, adjustments, t'orquing , etc. values within
.- prescribed ranges?
.(d)' Were any trends detectable in readings or component failures?
(e) Were problems / fail'ures caused by design, engine vibration, incomplete or. improper workmanship?
-A review of selected preoperational diesel testing was also conducted. This ,
review included observations of in process testing, reviews of test
. procedures, reviews of completed test procedures and evaluation et completed
- test data.
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During these reviews and evaluations of the diesel generators, a number of . problem areas were found to exist and are identified in the following report. In addition to specific problems / comments, which are identified, a number of ~ recommendations and observations are also included which should be considered for corrective actions. Although -some problems are 'still occurring during operation / testing, the
- frequency at which they occur seems to be decreasing. Additional testing and corrective action is needed to provide a high level of confidence that the engines will start end operate reliably. Specific comments and recommenda,tions are provided in various sections of this report. Section VI '
provides the specific recommendations for additional testing. Once these recommendations -have been adopted (in conjunctica with the recommendations of the LILCO Task Force), and the testing completed with no problems, this should
~
provide the necessary assurance that the emergency diesel can accomplish their design functions. As identified in _the recommendations of NUREG/CR-0660, the training and performance of personnel -(including Q/A) involved with maintenance and operation of emergency diesels contributed significantly to the reliability of , the various emergency engines. This same area appears to be a problem at
- Shoreham.
The Repair /Reeotk program including records was felt to need
-improvement.
Additional review and evaluation is also needed of various test results as identified in Section II. In addition, Section V.B provides reco:msendations for further investigation as a result of the turbocharger failure. 1 I t l, I
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, ENERGY CONSULTANTS, INC.
, FOR U. S. NUCLEAR REGULATORY COMMISSION REGION I Contract No. NRC Contract No.. 05-82-249 Parameter Purchase Order No. NRC-IE-82/83 Task 38 Docket'No. 50-322 License No. CPPR-95 t
[ i Licensee: Long Island Lighting Company
. 175 East Old Country Road Ricksv111e, NT Facility Name: Shoreham Nuclear Power Station
. Inspection Location: Shoreham, New York '
. Inspection Conducted: April 25, 1983 - May 19, 1983
. Inspector: [. .
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/M Gailard L. Runkle, Seni(r Consultant, Energy Consultants. Inc.
B. EcutomentIdentidie'ation: Manufacturer: . Engine - Transamerica Delaval Company Generator - Portec Electric Products Division Model: DSR-48 Serial Nud ers: 74010, 74011 and 74012 Ratings: -4,889 horsepower 3,500 kilowatts (continuous) 3,900 kilowatts (2 hour rating) 0.8 power factor 4,375 kilovole amps i 4,160 kilovolts 607.2 amparaga-C.
Background:
The three emergency diesel generators at the Shoreham Nuclear Power Station, Unic I, have experienced repeated problems during preoperational full load and endurance tests. The operational problems have included cylinder head 4
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problems (5 heads ' replaced), rocker arm assembly hold-down bolt failures, turbocharger bearing f tilure and linear indications in engine block casting. D. Inst,ection Objectives:'
, Provide an independent review and assessment of emergency diesel generator operability, and the ability of the diesels to perform their design function, based on a comparison of design capabilities / performance ratings (as described in the Shoreham Final Safety Analysis Report, design specifications and vendor
. technical manuals) with actual operational data (as ' described in licensee
. preoperational' test records). Witness ongoing emergency diesel generator testing, if applicable, and assess test results.
?arform an assessment of past preoperational problems, including material f ai.~.ures , and determine the appropriateness of corrective actions to provide
- assurance of futura diesel operability. Review, as appropriate. licensee
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reccrds of emergency diesel generator preventive and corrective maintenance
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set:ons since January 1,1981 and the licensee's written analysis of diesel fa1Jures and corrective actions. Assess the need for independent NRCicontractor material testing and for additional licensee material testing, i y as may be required. E. . Persons contacted: , l Long Island Lighting Comoany I E. Youngling
.J.'Rivello Secne & Webster Engineering Corcorstion l.
R. Purcell N. Rudikoff T. Paulantonio A. Stakutis l R. Lavrance W. Dick
- T. Brown J. Kamayer i 'W. Cook T. Gray ..
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Transamerica Delaval. Inc. . L. McHugh - R. D. Jacobs and Associates E. Jacobs
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U.S. Nuclear Regulatorv Commission { J. Higgins E. McCabe H. Nicholas L. Bettenhausen v }.* I f i 6 as I r 1 l
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- II. - TESTING
Background:
To verify the ability 'of the diesels to perform their design function, the operational data izi the preoperational test records were compared to the fdesign capabilities / performance ratings described in the Shoreham Final Saf ety Actual Analysis Report, design specifications and vendor technical manuals. casting was witnessed where possible.. Summary: Portions of testing on diesel engines 102 and 103 were observed over a period of two weeks. This testing was being performed in accordance uith In
' . preoperational test procedures PT. 307.003 B-1 and PT. 307.005C TCN-1.
-addition, the results of a completed test procedure PT. 307.005A were reviewed.- (It should be noted that the results of this completed procedure have not been reviewed nor accepted by the LILCO Joint Test Group.) The comments resulting from these reviews,are as follows:
Comment #1: The ~ Nuclear . Regulatory Commission Regulatory Guide 1.108 (Ravision 1 August 1977) Section C.2(3) requires the emergency diesel
- Senerators to be tested at a load equivalent to the continuous rating for 22 hours and for 2 hours at the 2 hour rating. The continuous full load I.
rating of each emergency diesel generator set is shown in Table Typical values of data recorded in PT. 307.005A for the full load run are l shown in the last column of Table I. . TABLE I
- Continuous Full Load Racing Test Lead Values t
3,500 3,510 Kilowatts (KV) 4,160 4,225 Volts (V) 607.2 480 I Amps (A) 0.8 1.0* l Power. Factor (PF) 4,375 3.513* Kilovolt-Amps (KVA)
- Calculated
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4,375) . and calculated KVA (3.513 vs. The low amperage (480 vs. 607.2) full load tested at its continuous shown, the diesel generator was not (Note: the power factor and KVA ratings. rating considering current, lower reading.) higher voltage of 4,225 would on37 acccune for a 10 amp ot fully Typical data for the 2 hour load run also shows basis.the Note: engine loaded to its 2 hour load rating on a current / power fuelfactor l During the 2-hour full load run at If the amperage load were racks were very near their full travel stops. increased, the fuel racks may have reached full trave , 110% amperage load was achieved. obtained during' the cast did not Note: The lower .than rated current load would probably have simulate a lower power factor). normal bus load conditions caused b, (actua heating, 8 The effects that are generator 1 1 ' heat loss. d therefore, were not effectively simulate . are capable of carrying their design To ensure the emergency diesels l testing should be conducted at the emergency 6.aergency loads, additiona 8 power factor. limits (voltage, amperage & KVA) while operating at a 0. to Step 8.3.7 of FT. 307.005A states load 1500 +diesel 100 KVAR. gener Comment # 2_: _ full load then' defines full load as 31 cord0KVAR
+ 70 KW so the Table I of the test procedure In addition, records KW but dess not reS l- data cannot be verified. 1 d of 3500 + 70, -
full load run, however, this step only specifies a . oa 0 KV and does not address KVAR load. then the generator eay If step 8.3.7 definition of full load is correct,l about 500 KVAR's were l not have been at full load in step 8.4.1 since on y should be the test. This inconsistency
.throughout maintained investigated and resolved.
In evaluating the recorded data, it was found t d amperage) did not always Comment #_3 : calculated Di (using the recorded voltage an
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' aset the acceptance criteria unless a power factor of almost one (1) was . ,
assumed. Some examples were observed where the voltage dropped and asperage decreased by about 10% and the recorded KW went up slightly - (KVAR would remain constant). These inconsistencies need further evaluation to determine if test requirements were actually met. i Comment #4: On April 27, observed that the official copy of PT. 307.005C in~use for diesel. testing did not contain TCN fl. (The step in progress had been changed by TCN #1. This TCN had been issued about two weeks earlier.) .
-Comment #5: The data st.eets in test procedure PT. 307.005C were not l signed by and therefore did not indicate who the data takers were.
Comment #6: Some instrumentation on the diesels being tested were not , marked to indicate their calibration status as required by ANSI N45.2 and N18.7. For- example, engine tachometer, cooling water charmameters. l i turbocharger air pressure, voltage, amperage and lube oil filter inlet and outlet pressure sages. l l Comment #7: Some data had been changed / corrected by write overs making, y it difficult to read.
~
e . . . Comment #8: - In test procedure PT. 307.005A&C precaution 4.7 states }. diesel room temperature and humidity should be frequently monitored. i
- There was no objective evidence that t.his was being done.
I L Comment #9: Initial condition 5.5 in procedure PT. 307.005C was signed off (with no exception indicated) indicating the HVAC was in operation. However, the ventilation was not in tormal operation as the ventilation
. damper was temporarily bypassed and failed open.
Comment #10: Step 8.4.1 of PT. 307.005A states " ensure total KVA of generator does not exceed 4375 KVA". Since there is no method provided to measure or requirement to calculate this value, it is not clear how l this requirement was met. . l {
l l Comment #11: The diesel generator load values in Table II of , PT. 307.005A are not recorded in the correct units. The table specifies
, _KW while values are actually recorded in hW. -
Comment #12: Various . steps in PT. 307.005A were designated to be vitnessed by Operations Q/A. The following steps have been completed but were not signed by Operations Q/A to indicate they witnessed the steps: 8.3.9, 8.3.11, 8.5.3 and 8.6.1. Recommendation #1: The readability of some of the test instrumenta tion
~
does not seem to be accurate enough to meet the test requirements. For example, the minimum subdivision for KW on the recorder was 200 KW while the tolerance band specified in the procedure was +40 and -19 KW. Similar problems existed for amperage and voltage. Test instruments should be accurate enough to be compatible with the tolerance of the acceptance criteria in the procedure, e . e, . . the readability of most analog instruments is one-half the smallest scale su::!ivision. The high speed recorder and charts should be analyzed ', verify that their accuracy will actually permit reading (interpola:6ng) these charts to
, ene-quarter or one-eighth of the smallest st: ale subdivision as necessary to assure compliance with the test requirements.
O e 6 8 e.
-9 I -
III. CORiECTIVE/ PREVENTIVE MAINTENANCE AND MAINTENANCE RECORDS .
Background:
- Approximately eight percent of the maintenance records (including Repair / Rework Requests, Rework Supervisor Work Summaries and Quality Assurance Verificatior. Reports) were reviewed to determine if the work was accomplished in accordance 'with all vand'or technical requirements. This review also determined if the maintenance and maintenance records properly implemented both local and NRC requirements. In addition, problems were reviewed to
. determine (where possible) if the " root cause" had actually been identified and currected.
Sunnarv: l In many cases it was not possible to verify, based on the maintenance records identified below, that the work had been properly conducted in accordance with
'both tachnical and administrative requirements. These problems fell into the following categories:
i
- 1. . Torquing -
The Delaval Technical Manual, Volume I, Appendix IV provides a table of torque values to be used for various threaded fasteners. This table also stated that all torque values are based on the use of a thread lubricant consisting of a 50/50 mixture of graphite and engine oil. Comment A: Some maintensuce records indicate incorrect torque values may have been used. For example, Repair / Rework 408 indicates the rocker arm assembly was only torqued to 120 ft lbs instead of . the required 365 f t lbs; Repair / Rework 417 indicates the rocker am assembly and sub cover were torqued to 365 ft lbs, (i.e., overtorqued) although the sub cover is only required to be torqued to 120 ft lbs. The consequences of over or under torquing should be evaluaeed. l~ I L l l i
Comment B: A number of maintenance records do not provide any . documentation or assurance that threaded fasteners were properly torqued since no torque values are recorded in the space provided - (Start-up Instruction No. 6) and since the records do not provide any reference to the use of calibrated torque wrenches (i.e., there l were no Measuring and Test Equipment (M&TE) numbers and calibratic due dates recorded in the- space provided). The following Repair / Rework Packages are typical of this type of problem: (1) 751 - no torque value and no M&TE number (2) 577 - no torque value and no M4TE number (3) 596 - no torque'value and no M&TE numbers (similst work on ,- 805 & 808 had required information) 1 (4) 554 - screes "no torque value, vendor specs" l, (5) 637 - no torque values recorded l (6) 712~- no M&TE number for torque wrench used on head studs (7) -394 - no torque values and no MATE numbers (8) ,423,- 3 no torque values and no M&TE numbers-4 s
- Comment C: A number of maintenance records do not provide any assurance that. the. required thread lubricant was used during
. reassembly and torquing. Some records specifically indicate "none" .
or '"NA" in the space provided on the form. Other packages did not 0 include a copy of this completed form to show a lubricant had been used. Start-up Instruction No. 6 ptovides a place for recording type er :hread lubricant. Typical examples are found in the following Repair / Rework Packages:
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l l 4 (1): 612 and 744 - indicate lubricant was used on head studs, . other studs and bolts were not aldressed (2) 712 - states "none" '
\
(3) 670 - states "NA" (4) There is no reference of any lubricant in packages 596, 360, 359, 511, 636, 637, 714 and 820. Comment D:. In many of the maintenance records, the Quality Assurance- verification report is so brief or general it is not
,possible to determine 'what was witnessed and verified.
~
Typical examples are found in the following Repair / Rework Packages: 612, 349', 351, 360, 670, 712, 423 and 577. Comment E: Some maintenance records indicated repairs and/or inspections were performed but the acceptance criteria is not clear. Typical- examples can be found in the following Repair / Rework Packages: (1)- 751 - A jacket water pump tas disassembled and the pump impeller was " inspected and found to be satisfactory". It is not clear what this acceptance was based on since no
. measurements were recorded and instructions do not specify' what kind-- of- inspection to perform (i.e., visual, asasurement, dye penetrant).
. -(2) 546 - During repairs to a jacket water pump, this package .
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states " started lapping and blue checking bore to shaf t. Attained 85% contact on blue check." No reference is made to any acceptance criteria for the required percentage of contact.
- 2. Maintenance Precedures - Seieral Repair / Rework Packages were found which indicated the. repair work had been pqrfor=ed in accordance
'O with verbal directions from the Delaval service representative. The ,
specific directions or adjustments were not normally recorded making it impossible to verify that the work was completed in accordance - with - the technical specifications in the Delaval service manual. One example was found where a thrust reading outside the specified tolerance was apparently accepted based on verbal direction of the vendor. Typical examples of these problems are found in the following Repair / Rework Packages: i Conssent A: 590 - The vork sumary in this package " checked total thrust of rotor assembly - 0.007* (okay from Al Scott Delaval representative)". A Delaval letter of December 6, 1982 (attached to LDR-926) states the Elliott specifications call for a thrust of 0.008 to 0.018.- Comment 5: 374 - The work summary in this package states " adjusted rocker arms accordingly as per Delaval representative". Comment C: 546 - The work sumary in this package states " installed watcr pump with new gasket, tighten down bolts to representative appreval".
- Comment D
- , M - This package documented disassembly a jacket water pump for inspection and replaced the impeller nut. The work summary states "no torque value, vendor specs".
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IV. VISUAL INSPECTION OF DIESEL GENERATORS .
Background:
Visual inspections of each diesel generator unit was performed. When possible, inspections were also performed while the engines were running. These inspections were performed to determine the general condition of each engine and detect possible abnormal conditions. Susumary: While no major problems were observed on any of the engines, so ne conditions were noted which .should be corrected to ensure future problems do not oc: cur.
~
Several other conditions were observed which should be evaluated to determine the 'need for further corrective actions. Comments resulting from these inspections are as follows: Comment it: Many instrumentation, contr21 and gage lines (1/4 inch to 3/4 inch size) are inadequately braced and vibrate excessively during operation. Some lines appear to need additional brackets while others have been removed from the brackets provided and were never reinstalled. For example, the lube oil supply line to the turbocharger failed due to
- vibration while in its design brackets.
Comment #2: A label plate on each diesel specified required torque values.- These values do not all agree with the torque values currently in the technical manual. l t Cocaent #3: Some bolts on the air inlet elbows to the head were loose
.and partially unthreaded apparently due to vibration during operation. -
Some bolts had washers, some lock washers and others no washers. The application of washers and/or lock washers should be specified. i s ee
w V. : REVIEW OF COMPONENT PROBLEMS / FAILURES A. Engine Head Cracks . Backtround:: LILCO Deficiency Reports 1040, 1065, 1056 and 1141, various Repair / Rework Requests and correspondence with Delaval documents the identification of
' cracks in three cylinder heads. The Delaval Failure Analysis Reports indicate the ' cracks found in the three cylinder heads occurred as a result of annufacturing defects (hot tears resulting from sand inclusions in the casting and uneven cooling). The small amount of leakage that might occur would be blown out with the exhaust. Since these cracks were self-ralieving and non-propogating, Delaval stated they would not affect operability or availability
. in . stand-by service.- The Delaval reports also indicate improved casting, manufacturing and testing techniques would preclude cracks in the latest head i design. ,
LILCO letter SNhC-873 indicates that a leak detection procedure reccamended by ' Delaval will be implemented until the permanent corree,tive action can be accomplished. This permanent corr 2ctivet action will install cylinder heads of the latest available design. , Sunsaary: LILCO's corrective action of installing the latest design heads should f I eliminate this problem once . the work is complaced. This work is currentiy 6- scheduled . to . be completed on a non-controlling basis. The leak dacection procedure recommended by Delaval would identify any future cracks should they . occur. . [ Based on a review of the actions being taken by LILCO, sdditional independent NRC/ contractor material testing is not recommended, i 4 e e 4 L - _ . _ _ . ~ . _ - _ _ _ _
N . Recommendations:
! (a) Since water leakage / build up into a cylinder during long idle -
periods could have drastic consequences in an emergency start, it is recommended that if an engine does not have the new design heads installed, then it should be barred over with the indicator cocks
.open on a weekly basis af ter reactor critical testing has started.
This barrir. procedure, in conjunction with the barring procedures ' recommended by Transamerica Delaval, should assure the engines will operate satisfactorily with the existing heads. - (b) Since Delaval has indicated stricter manufacturing controls assures the new heads are a high quality product, consideration should be given to either auditing or monitoring the production of some of these new heads or performing ~ detailed receipt inspection and testing of one or two of these new heads. i i B. Turbocharger Failure .
~
Background:
l LILCO Deficiency Report #926 documents the failure of a turbocharger thrust bearing. The initial evaluation by Delaval indicated the failure occurred due to a missing guide vane on the nozzle ring. A subsequent report from the turbocharger manufacturer (United Technologies Elliott) concluded the missing l blade (vane) had failed in service apparently due te nachanical fatigue. In addition, Elliott indicated that sdditional analysis was being conducted on
, the nozzle ring and that pressure and camperature readings just upstream of the turbine inlet easing during a rapid start-up cycle would be helpful. .
l Summarvt i l Based on the type of failure '(mechanical fatigue), it is recommended that this ( not be considered an isolated occurrence until it has been determined exactly what condicione caused the fatigue failure. l '
.O-
; Recommendation:
Consideration should be given to: - (a) Checking the other turbochargers for possible cracking (b) Evaluating the possibility of the missing blade having been knocked back into the-exhaust manifold as postulated by Elliott. C. Engine Block Casting Indications Backeround: LILCO Deficiency Report #1224 and Repair / Rework Request numbers 867, 868, 369, 870, 871 and 880 provida- the details of Stone & Webster Engineering Corporation's (S&W's) investigation and engineering evaluation of linear indications which were found in the can galley area of the engine block
- casting.* The investigation required the indications on each engine to be checked and mapped using non-destructive examination. A similar design engine l, .
_ with'a substantial number of operating hours was checked by S&W engineers using nondestructive awa=4 nation. Indications were found of the same
= approximate size with no evidence of any propagation. S&W engineers found similar indication on a new engine block casting at the factory. This shows the indications occur during manufaci.ure and _ are not a result of operations.
Calculations by Delaval showed the regions where the indications are located .. are subject to compressive stresses which would not cause the indications to propagate. Discussions with S&W 1ead engineers indicated Delaval is conducting tests on an operating engine in order to verify their calculations and will issue a report when 'this testing is completed. Based on their . P evaluation of these indications,. S&W has concluded that this indication will
< present no problems _ to the operation and reliability 'of the emergency diesel 1
generators.
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I i l .
Summarv: Af ter a review of the actions taken by S&W and Delaval and discussions with ~ the S&W engineers, who conducted the evaluation, it is felt that their actions w' era adequate and the conclusions correct. However, the test results should be reviewed to ensure they verify the calculations. ' D. General Review of Problems .
Background:
. During the detailed review of various Deficiency Reports, Failure Reports and Repair / Rework Requests, a significant number of problems or errors have been identified which seem to have occurred due to errors and incomplete or' improperly completed work by the manufacturer. Attachment I to this section provides examples of specific problems that fall into this category.
Summary: (
; , A large number ' and variety of problems that have been 'exper'ienced can be i
attributed to vendor workmanship. These errors, in conjunction with the problems identified during audits of Delaval's Quality Assurance Program (audits /reaudits conducted October 1975 February 1976 and June 1976), indicate a weakly implemented Quality Control Program. Recommendation: . l Although the number of problems is decreasing significantly, they have act been completely eliminated and, therefore, reliability has not been - demonstrated. Based on this, strong consideration should be given to continued operation or testing until problems have been eliminated and the engines run reliably. Once the required testing has been completed and all problems corrected, at least one engine should be started and run for the design seven days at a nominal lead of 3,500 KW. _ - - . - . , , . . - ~ - - - .. . . , -
The actions taken b'y Delaval to eliminate these. quality-related proble=s . should also be determined and . evaluated. This would ensure problems with future spare parts will not occur. - To provide the confidence factor that the emergency diesel engines will
- operate reliably, the periodic surveillance testing should be increased to I perform a four hour -load test each month. If at the end of six months no failures have occurred, return to the surveillance casting specified in the technical specifications.
4 e d l -
r ATTACHMENT 1 . GENERAL REVIEW OF PROBLEMS - 394 - A meno . in this package from a - Delaval representative indicates the casing discharge on a jacket water pump was found partially blocked by excess casting material. 442 ESDCR-F41289 - attached to this package indicates Delaval supplied a jacket water pump witL the wrong impeller. 551 - (See LDR-0832) - A memo attached to this package indicates a jacket water pump had been assembled with an extra washer behind the impeller castle nut and that the impeller had been machined to the wrong drawing which had been provided by Delaval. A second pump failed and investigation showed the impeller had been improperly installed at the factory. 577 - A Delaval Failure Analysis Report (attached to E&DCR-F43525) indicates the jacket water pump shaf t failure was induced by an improperly tightened impeller hub nut. (There were no records to indicate this punp had been disassembled since it left the factory.) l LDR-816 - This deficiency report indicates incorrect springs were installed on i the internal relief valves of the engine driven fuel oil pumps. t l 359 and 360 - (See LDR-654) - During a pre-start inspection of the gear cases, it was found that two of the engines were missing some fitted bolts required , on the can gear. Delaval drawings require drilling holes and installing and t torquing these bolts after final engine timing. . 701 & 702 - (See LDRs 1006 and 1024) - During inspection of the Governor Drive assembly, the following problems were found: " j (a) Coupling grid was broken due to misalignment of the governor (b) A key of the wrong size was found installed on one engine
9, ATTAC1DiENT 1 (CONT'D) (c) A coupling half was found pinned to the coupling adapter although ' this pin was not shown on the Delaval Drawing. 712, 744, 408, 636, 661, 663, 670, 714, 715 and 717 - (See LDRs 1040, 1065, 1056 and 1141) - Part of the problems with the cracked cylinder heads was attributed to manufacturing defects and thin castings. The factory l inspections and testing had failed to identify these deficiencies. 046 - (See LDR-0503) - Lube oil cooler tubes leaked due to improper rolling of tubes into the tube sheet which were not identified by vendor quality control.
= 236 - (See LDR-0560) - The lube oil pump suction line on one engine was found
,,_ without a drilled passageway for the relief valve. This problem was attributed to an oversight at the factory. { 351 - During a routine sear. inspection, an extra loose bolt was found in the gear' train. The bolt was badly beaten and chipped.
= -. .
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VI. GENERAL RECOMMEN9ATIONS - Backaround: - DurinS the review of the Diesel Generator operations, testing and maintenance, a nesbar of conditions were observed which did not specifically vio' late or deviate - from requirements but which did, in the opinion of the inspector, indicate weakness or areas which could be improved. Other conditions in this category are chose for which insufficient information was available to make a judgement and should be considered for further evaluation. Summary: The following list of observations and recommendations should be considered '. for further evaluation and/or possible correctivc action: Recommendation #1: Repair / Rework Requests do not reference specific repair procedures. They normally only reference the Diesel Construction specification SHI-089. This makes it difficult or impossible for either Q/A inspectors or other reviewer / auditors to determine what instructions were actually to be followed. A system that requires identifying the specific repair procedures would be a major improvement. This would allov Q/A personnel to review the specific procedure and establish hold / witness points as necessary. This could be similar to the procedure for Maintenance Work Requests. Recommendation #2: Eased on the probleas identified in the L975 audit of Delaval of the failure to have calibrated torque wrenches plus the lack of adequate documentation in maintenance records for torque value makes . it impossible to ensure all components have been properly torqued. Based on ,the work conpleted to date, it is recommended that all components / parts should have their corque values verified by analysis or tests. Recommendation #3: As stated in otha.r sections of this report, some problems or failures are still being experienced when an engine is run for testing. Some problems result in the engine being shutdown for
*~
1 convenience to correct the problem. Other problems such as lube oil line . failure and jacket water temperature pneumatic switch failure resulted in 1 immediate engine shutdown. Testing / operation should continue until the - engines all operate reliably. After all work and testing is completed, it is recommended that at least one emergency diesel generator should be started and run for seven days at about 3,500 KW. If a failure occurs, testing should . continue until all three engines have demonstrated their ability to operate reliably under load for the seven-day period. Recommendation #4: Obtain the results of audits performed on Delaval by other utilities and evaluate their findings and corrective actions (i.e., Texas Utilities, Gulf States Utilities and San Diego Cas & Electric). Based on this information, determine the need for further additional audits of Delaval. , Recommendation #5: The engine exhaust inlet and outlet elbow from the ! turbocharger are uninsulated and cocid present a fire hazard from a fuel oil or lube oil line failure. The need for insulating this area should
.be reconsidered or some other assurance provided that shows such a fire
'could not occur.
Recommendation #6: There is a substantial opening (about four (4) inches wide and several feet long) betwear the flywheel and the protective cage around the generator. Sface this opening is on the top of the generator adjacent to the baring device, it presents a possibility of items falling - into the generator causing damage or short circuits. Consideration should be given to install a protective cover over this opening. Recommendation #7: In several of the problems / failures which Long Island Lighting Company has experienced. Delaval already had an improved / upgraded replacement part which effectively eliminated the problem. S&W and LILCO should make a strong effort to have Delaval supply them with a list of modifications, design changes, product upgrade, etc. which have been made to this type of engine since the LILCO engines were l manufactured. LILCO and S&W could then review this list and decide which j of the modifications they want to implement. I
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y t i 1 Recotanendation #8: During operation, a significant number of fuel oil and . , , lube oil leaks are apparent. These leaks keep one individual busy r cleaning up. During an emergency, personnel may not be available to keep - these leaks cleaned up. This could result in substantial accumulations presenting a fire hazard. Action should be taken to eliminate as much of this leakage as practical. 4 i Observation #1: Some of the LILCO Maintenance Support Division personnel have completed a diesel maintenance training program a few months ago. There was insufficient time available to determine the diesel experience or training for maintenance personnel from the construction groups who have also performed repair work on the diesels. Observation #2: As noted in other portions of this report, there are examples that vendor field representatives operate somewhat informally at times in directing repairs. While he is assigned in the field, the Delaval representative is not clearly under the umbrella of the Delaval factory quality assurance plan. The utility (LILCO) personnel tiend to accept his comments / actions since he is the " vendor expert". When a Delaval reprasentative is performing or directing work at the site, his actions should comply with the LILCO Q/A Program just the same as any other plant worker. Observation #3: The jacket water pumps do not have unique serial numbers making it very difficult or impossible to maintain traceability especially during multiple pump changeouts or maintenance. ' Observation #4: The FSAR response to NRC question (request) 223.85 states, "As shown on Figure 9.5.7-1, a check valve prevents lubricating , oil from being circulsted through the turbocharger" when shutdown. However, a " subsequent modification (E&DCR F-34540) has now added a small , lube oil supply to the turbocharger in the shutdown condition. This response and figure should be reviewed and revised as necessary. l
- Observation #5
- In general, it was felt that the quality assurance, l engineering and testing administrative procedures that applied to l
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start-up activities were weakly implemented.
~ A specific concern is the
- fact that most of the problems identified in this report have existed for over a year and were not identified and corrected by supervisory reviews -
or the audit program. O
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1 1 i I O L I ATTACHMENT 6 I I i l e 1 i l I i l I 1 I I 1 l l l l t I I
Q ) I [gB,g LONG ISLAND LIGHTING COMPANY EXECUTIVE OFFICES: 250 OLD COUNTRY ROAD
- MINEOLA, NEW YORK 11501
;SIBl E28 -224.4 EDwamo 64. mAmmCTT
.... cou m December 2, 1983
)9O k f 0
l Robert E. Smith, Esq. 'ss 0%J' S
- Guggenheimer & Untermyer N, ',7 ; '% .( 4 '
80 Pine Street 0" New York, New York 10005
Dear Mr. Smith:
This letter is sent to you in your capacity as counsel to Transamerica Delaval Incorporated (Delaval). As you know, on August 12, 1983, the crankshaft in emergency diesel generator 102 at our Shoreham Nuclear Power
- Station failed in the course of performance tests of the engine. LILCO retained Failure Analysis Associates (FaAA) to conduct a thorough investigation of this failura. In the course of this investigation, cracks were found in the crank-shafts of diesel generators 101 an.1 103 as well.
FaAA's final report on the cause or causes of the , crankshaft failure demonstrates that the crankshaft failure occurred as a result of inadequate or defective design. FaAA also investigated cracked connecting rod bearings and cracked pistons discovered on the engines. FaAA's interim report on the cracked bearings indicates those failures occurred as a result of a combinr. tion of causes, including inadequate or defective design and manufacture. FaAA's investigation of the cracked pistons and other matters observed in the inspection of the' engines is continuing, but preliminary indications are'that these, too, occurred as a result of defective or inadequate design. Prior to the crankshaft failure, LILCO had experienced a number of occurrences attributable to defectively designed or fabricated diesel generator components, including three leaking cylinder heads, defective jacket water pumps, leaking fuel oil injection lines, inadequate turbocharger thrust bearin5 lubrication, inadequate piston skirt to piston crown attachment, broken rocker arm shaft bolts and cracked sub-cover assemblies. While these occurrences were generally of the type experienced in the shakedown of large diesel engines, they appear, nonetheless, to be attributable to defective design or fabrication. 6 i
(
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3.' )
.- Robart E. Smith, Esq. Dscs:mbar 2, 1983 Based on'LILCO's currently available information, LILCO believes the defects in the diesel generator sets provided us by Delaval constitute.a breach of the contract between LILCO and Delaval for the purchase and sale of those diesel-generator sets, including but not limited to a breach of warranties contained in and arising out.of that contract. '
This letter is solely for the purpose of providing notice of the breach. Nothing contained herein should be construed as a release of any other claims that LILCO may have against Delaval or as a waiver of any rights and remedies LILCO may have in this matter. Although LILCO is now giving Delaval notice of claims, we believe it is in LILCO's and Delaval's best interests to pursue aggressively the prompt repair and
' licensing of the Shoreham diesel generators. We believe substantial progress has been made toward this goal and hope that Delaval and LILCO can work-together in the future to complete this important project.
Sincerely, U k'l EMB:lbs Edward M. Barrett l l I p I
ATTACHMENT 7 i S w
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.i . t. NUOLSAR MGULATORY COM 4ISSION 5 ] :.';nsnmcict;. c. c. :sst S.3
' '? '.h. . '
Octeoer II, 1983
/
k Docket No. 50-416 MEMORANDUM FOR:. Chairman Palladine" Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine Cc=issioner Bernthal FRD'.: Carrell G. Eisenhut, Directer Division of Licensing SUE.ECT: NEW INFORMATION CONCERNING TRANSAMERICA DELAVAL (TDI) EMERGENCY DIESEL GENERATORS, BOARD NOTIFICATICK 83-160 In accordance with NRC procedures for board notifications, the folicwing information is being provided directly to the Commission. The appropriate boards and parties are being provided with a copy of this memorandum. The inferratier, is acclicaole to Grand Gulf (an uncontested case), which will be
~ befcre the Cor.ission fcr full. power authorization in November,1983.
t On August 12.-19E3, during post-modification testing, the main' crankshaft on ene of the three emergency diesel generators (EDG) at the Shoreham Nuclear Fower Station failed and broke into two pieces. The applicant subsecuently inspected the_ remaining two diesel generators at Shoreham and identifieo additional flaws in the crankshafts of those nachines in locations similar to Lha failure-of the first machine. A more detailed description of the failure is contained in Enclosure 1 (IE Information Notice No. 83-58). The EDis at Shoreham were manufactured by Transamerica'DeLaval Incerporated (TDI). TDI has also previded EDGs to several other nuclear power piants (see Enclosure'1). The only currently operating reactor with TDI diesels is Grand Gulf. The TDI diesel at San Onofre is used by Unit 1, which is shutdown for seismic modifications, and the dieself at Rancho Seco are not yet installed. tesides the failure of the crankshaft at Shoreham, the staff has noted the cccurrence of many minor problems with TDI EDGs, which are suttrized in Enciesure 2. The s aff would expect minor problens.to occur during the startup testing of any large piece of machinery, such as a diesel generater, but the nucher of cinor problems experienced by the TDI machines in nuclear rarvice appears to be abncrmally high (also See Enclesure 4). 8308310050 l L
e- . t -s 2 Ace'ticr. ally, curing vendc- ir.s;ect'nns c' TDI which were et #e re rccer.tiy h Regier :Y, 'r response te elleoetirrF. 'he ctaff identified ccnditiens
'wnich ' imply tnat portions cf the TDI Duelity Assurance (CA) Procram have net b+en carriet out in accordance with the provisiers c' 10 CFR 50', A;;endix 3.
. Regien I'l has referror' *.h* CA prchiers to the Office ef Irvestigations, which has requested that details net be revealed to avoid cerrrr.rdsing the in-vestigation. As e result of an inspection performeri in July 1983, the staff
'dentified a potential violation and several potential nonecr#c-rences v.t.ich-are described in IE Inspection Report lio. 99900334/83-01, dated Octeter 3, 1983 (Enclosure,5). ,
The Shereham applicant is investigating the crPrkshPft failure, but does cet er.;er.t te publish a report v
- 1 later in October. The staff has asked the a;;*icar.: to*accrass a ser'.ss of cuectiert. cencernir; t5e Shcrehr.r E".3 cagigr, fabricatien, cperation, and maintenance in itr. #ailure report (see Enclosure 3). A similar list of ouestiers is being developed for other applicants.
The identificatien of OA problems at TDI, taken tocether with the number of
. operational prchlers P.nd the Shoreham crankshaft failure, has reduced the-staff's level of confidence in the reliability of all TDI diesel eer.arators.
The staff will recuire, on a case by case basis, a demonstration that theso
. cencerns are not applicable to specific diesel generators because cf sub-secuert insoections or testing perforr.ed specifically to address the thrve
, ma tters . Further developments and additional information en this sub.iect will be reported to the appecpriate Boards.
9-
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i e T.'Eiserhut',Yiector Division of Licensing Enciesures: (1) IE Informatinn l'eti et P3-52 (2) Sumnary of DeLaval DG . Problems (12/80-8/83) (3) Sun.ary ef September 2, 1983 EDG Meeting on Shoreham (di IE Information liotice 83-51 (5) !E Inspection Recort f!c. 99900334/83-01 With Octcber 3,19E3 Trar,smittal Letter to Trans America DeLaval Inc. -
-cc: See next page
ur : gj '% cc: SECY' OPE OGC EDO ASLB FOR: Shorenam 50-322 (Brenner, Ferguson, Morris, Laurenson, Kline, Shon) Perry 50 A40/441 (Plech, Bright, r,line) Co:r.anche Peak 50-445/446 (Bloch, Jordan, McCollan) Midland 50-329/330 (Bechhoefer, Cowan, Harbour) Ca tawba 50-413/414 (Kelley, Callihan, Foster) . Clinch River 50-537 (Miller, Hand, Linenberger) ASLAB FOP.: Snorenam 50-322-(Rosenthal Edles, Wilber) Clinch Ri.ver 50-537 (Edles, Johnson, Wilber) d e l 4 m b O l .
ENCLOSURE 1 551NS h:. EEIE
. 1H E3-55 -
t
- UNITED STATES NUCLEAR REGULATORY CDPXISSION OFFICE 0~ IN5?ECTION AND ENFORCEMENT
. . WAS:-:INGTON, D. ~. 20555 August 30, 15E3 1
IE 40p.MATION NOTICE NO. 83-55: TiiAN5 AMERICA DELA7AL DIESEL GENERATOR CRANKSHAFT FAILURE l . Acdressees: .
-Al' ~ nuclear power facilities holding an operating license (OL) or a construction pe =it (CP).
Fur:cse: - This information notice is provided to bring to the attention o' flicensees and ccnstruction permit holders a recent event at the shoreham Nuclear station in whien a- diesel generator crankshaft failed during post-modification full load testing. The Nuclear Regulatory Cemission staff is reviewing the problem and
. its effects. If the evaluation so indicates, the NRC may reouest explicit licensee or CP holder action. In the interim, we expect the addressees of this infermatien netice to review the information herein for applicability to their facilities..No specific action or response is required at this time.
. Descristion' of Circumstances: -
' Af er-installation of eight new cylinder heads, emergency diesel generator'
' (E G) No. 102 failed during post-modification testine wh:n its crankshaft -
4 - assemblyfracturedatthecrankpinandcrankarm(web}onthegeneratorsideof- l the Cylinder No. 7 crank. This failure occurred during the last 15 minutes of testing at the two-hour overload rating. EDG-102 had a total of 12 hours and 25 minutes of'two-heur overload testing When failure occurred. Its installed l :ra .cshaft assembly has a crankshaft diameter of 13" and a crankpin ciameter_ cf 11". . Replacement crankshaf t assemblies with 12" diameter crankpins are being procured.' , \ Subsecuent to this failure of EDG-102, the licensee examined the crankshafts of the two other diese1 generator units at the Shoreham site, EDG-101 and EDG-103
. by cpening the crankshaft area. The examination of the ED3-101 crankshaft i . assembly _ showed cracking on the Cylinder No. 7 crankweb (generator side)
- and'cye penetrant indications on the cranks at Cylinder Nos. 3 and 5.
E). amination of -he EDG-103 crankshaft assembly icentified a crack about 2" long and 3/8". deep on the Cylinder No. 6 crankweb (governor side) and a cen-ne: ting rod to erankein bearing failure on cylinder No. 5. The bearing failure i.
- dr.c*.ved breaking off of approximately a 1" x 3" piece and everheating cf 6
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~ ' ' IN E3-58
, s Augus- 20. 15E3 Page 2 cf 2 the surr:ending area for about 2". M:st of the other cracks fcund are 'simi",ar it ' *.::t-ict and crientati:n to the one which resultec in EDG-IC2 crankshaft assem:1y-fracture.
Trar.samerica Delaval reported that the following nuclear sites have Transamerica Dela -1 diesel generators: Shereham. Perry - Midland Grand Gulf Bellef:nte Hartsville Ca awst WPP5 Phtpps Eend
. San Onofre Comanche Peak River Bend -
Vogtle Rancho Seco . Shearon Harris Clinch River The reliminary information from the manufacturer is that the diesels at Sheraham, F.iver Bend, and Rancho Seco= are eight cylinder in-line engines. Ecwever, the crankpin diameter is 11" in the Shoreham units and 12" in the ur.its at the other two sites. The diesel engines at the remainoer of the sites listed above are of a "V" design and have.12,16, or 20 cylinders.
. The shaft material for all the engines is the same, with the possible excep-ion
- f the 20 cylinder engines. All the engines are designed to have appr:ximately the sa:a brake mean effective pressure. The torsional systers of the engines differ. At this time it is not clear to what extent other diesel generators,
.'sanufa:tured by.Transamerica Delaval are vulnerable to the same or similar .
failures as these experienced by the Shoreham engines.
-If you have any questions regarding this natter, please contact the Regional Admir.is rator of the appropriate NRC Regional Office, or this office.
. - ,: W"'
, . . , , . . : . s.
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Edward L. Jordan, Director
. Division of Emergency Preparedness ar.d Engineering Respense Office of Inspection and Enforcement Technical
Contact:
W. Laudan, IE (301) 492-9759 At achment: .
*is cf Recently Issued IE Information Notices-
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OE/12 /E3 s Crankshaft failure e seing inves: iga:e: , e cause unknown, as ye: e Snorena: EDG-102 - 0 /20/E3 e holdcown capstrews, rocker arm assy. e reciaced wi n new dest:n
- e Shorenam EDG-103 e TDI says iscia ed failure
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e water in cylincers - e TDI says n: affe:: cr. e Shoreham EDG-101,-102,-1CI - 3/03/E3 e hi-press fuel line e resinced with r tw desigr. e manufacturing defects fuel line w/s eei snr:ut e Shoreham EDS-iO2,-103 . e Also failed.at Grand Gulf on 8/2/83 12 /i3/12 e unqualified c:n rci cabits e re::r e: ty 3 rand 3;1f cniy e failed IEEE ' flame tes- - 01/17/12 e jacke: water ;c:p shaft failures e new desi; af er f.:reigt. f ai*i sre e fatigue cracking et snaft keywey e new cesi;n failst , e Snoreham E33-iO2 (50 nours', -103 e 3ro.cesign inciu:es: new (170 hours) - i=;eller =a t') . , rs=evin g shaft key, site c# hub wather, new asse :*.y ir.str.::i:r.s 07/22/S2 e hi water jacket te=p. trip e design deficiency e closed cooling outlet valve e incorrect valve pos. indication
. e . Grand Gulf Div. 2 05/23/52 e governer flex, drive ceuciing e replaced w/ neoprene e misa: plication of materials e ist:rene inten:ed for at s;5eric .
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e sting use: at ni-te::. cil , environment inside gear case e Grand Gulf . P
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, e Grand Gulf l2. * ! *i2 -e 1:ss :f.startin; air ($ ming es' e7: re:: . ..:s -es t 4::s e; e sensir.; itne net seismically :ri f t :e :: s.'. ca : . e t: :own qualified :t e :: 53 =ir.v:ts ar.:
- frat:r a::i:r. : is:'g t itne s
ci/15/E2 e sheared bolts , rear craa.hshaf t e 701 sai: vibra-i:n ces :: - cover firing :f rear cylin:er e Grand G.if, 2*-hr. :es r r. e 't:::f r.:er.: :ests s.: t: n: in:r: r.a:a vi:ra:i:P e swi Or.t: *: hi;*tr rtr.;;r. (i:,::* :st) ca-::n sitt'.
- 1 s -
e fatiurs :f 50,000 :st ::1 s new e).:e::et
- e !i:LL now using 150.00: :si ali y steei 5:'.:3, w':n ;r:;te
.hta: treatment re::r:s 12/g;/li e g:vern:r lebe oil copier assy,
- e .T:1 re::::ents i: er ::gr.:tn; e air trapped in lines loca-for
.e i= pre:er mounting location
*1/05/11 i pis :n cro.n separated fr:s shir; e 7 1 cestyr. :han;e: ::
e fatiure of a acament stud belts !stievi de wasners (5tryi:t e improperly efgd. spnerical washers Inic. Me:: uc. 324) e cy'.in:tr liner gro:ving e 701 says de:ris during as semb*.;. or initial star:v: o grooving of crankshaft bearing e TDI says "transien; mat'1'."
, crank pin discolored in tube oil e cylinder link rod wris pin grooved e 70! says bleckage of iube cil .
- and pitted; wrist pin discolored f reign ma ter in Ivet eil e Grand Gulf 0 /14/52 e fire-luta cii spray a crackte instr. line e vi: ration e SC"GS-i e
e 4 . e: , e .6H - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ . _ . _ _ _ _ . _ _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ __ . _ _ _ _ _ ________._______..._______.__...______._s
s .
- s. .' .
e n . i t 12f} } j i'. e use cf n n-c.:a*.* fie: :sters e ::,:-s a. Gran: 1 ' ' :t ".; , e aus., iu:e e11 ;u.:, aux, jacr.t, en:1 ::: :y : ,- water :::: e TDI suniied ::6tri:ai gra:t ::::rs wi r, "e:vivaier.:y" .s. Class II r.o: rs
- i e Equivalency data retracted 12/15/20 e Turbocharger luet eiT sys. ecasign.cstt:g;ign;3),7_,g e luce grains out Of :nrust bearings pes-1;;:e f:r gg starts during standby :peration ,
e c:cassional " fast s arts" ' e :austs excessive wear
- a::e- able ,
e 50::15-1 , 8 > G 5 t 9 6 e a e ) e O 6 4 0 0 5 9 4 9 t e s
. r 6
6 5
,, ENCLo!URE 3
- g,P o.eee6), UNITED sTATas t
NUOLE AR REGULATORY COMMIS$10N jy . b, #g . . c o..> e. ...
\ .' , , # -
SEP 2 f.155
, Occket Nc.: 50-322 t.P.LICANT: Long Island Lighting Company
' PACILITY: Shoreham Nuclear Power Station .
SUEJECT: SUM".ARY OF SEPTEMBER 2, 1983 EMERGENCY DIESEL GENERATOR MEETING Cn se: arber 2, 1983, a team composec of NRC staff me::ers from tne Offica f Nuclear Reactor Angulation and from the Region I office, and NRC contractors, met with rept-esentatives of the Long Island Lighting Comoany (LILCO) to discuss LILCO's plans to investigate the cause of the failure of '
' the #102 Emergency Diesel Generator at Shoreham. A litt of attendees is enclosed (Enc osure 1).
On August 12, 1983, durity a load test, the main crankshaft of the #102 EDG failed. Subsequent inspection of the #101 and !103 EDG crankshafts revealed cracks in locations similar to that of the break in the f102 crankshaft. , An investigation of the cause of causes cf the failure is underway and will be conducted in accordance with a master plan (Enclosure 2) which generally describes the steps to be taken. LILCO intends to use the resources of appr::riate LILCO organizations, Transamerica Delaval (TDI), Stone &
- Webster Engineering Corporation, and appropriate contractors to carry out the steps outlined in the mastar plan. Failure Analysis. Associates (FAA) will conduct the investigation to determine the cause of'the crankshaf t failure and the cracks.
idr. Young *ing described the various phases of, the program, which include an independent review of the crankshaf t torsional design by FAA, an overall design review of the entire EDG, and a review of other crankshaft failures. He reported that FAA's torsional analysis results, to date, agreed very closely with both the TDI torsional analysis and with the values measured by TOI in a torsional test run on the #101 EDG at the 70! factory. LILC0
, has decided to use the #101 EDG as a test-bed.to gather additional torsional test information and was in the process of instrumenting the machine at the -
time of this conting. The test data will be used to verify analytics1 models anc to try to ccrrelate the observed problems with the effects of previous * , EDG qualification testing. O g e6 494 86 8 i
,7 ' ' .. g ..
. 2-Me .sers cf the NRC staff discussed some of the philese:hy behind the EC3 test recuiremer.ts contained in the Aegulatory Guides, and explained the need to understood the potential generic implications of inase failures. The staff is cencerned that the failures may indicate a deficiency in the TDI design rocess which may show up in other TDI diesel generaters in other nuclear power plants. The staff then presented LILCO with a list of questiens and concerns which must be addressed before the staff can have confidence in the ability of the diesel generators (Enclosure 3). LILC0 was requested to respond to these items as qu'ickly as possible, as the necessary information ' becomes available, and Mr. Youngling'and Mr. Museler assured that that could te done.
Mr. Museler reported that TDI had ccmmitted to prcvide LILC0 with all the su::ert notessary te solve this prc31em. He also ex:itinec that FAA woulc ha t..a team lendar and that it had been instructed to :ensider all pessible failure mechanisims and root causes, and not arbitrarily dismiss unlikely causes. Mr. Dynner and Mr. Christensen, represanting Suffolk County, asked several questions concerning the design of the machine which LILCO promised to
- answer, and were assured that they would be prom:tly notified of tne results of the inspections. The staff concluded that LILCO's plan appeared to be basically sound and proceeding in the right direction.
/ b.
sil *4'M.
?
Ralph aruso Project Manager Licen ing Bran:n No. 2
, , Division of Licensing
Enclosures:
As stated . cc: See next page
- t
-4 e
e,
- q s 3
1
,- )
- c. .' ,
t l Shorenam Mr. M. 5. Pollock Vice President - Nuclear Long 'sland Lignting Company 175 East Old Count / Road . Micksville, New York 11801 : c c. . Howard L. 81au, Escuire MHS Technical Associates Blau and Cohn, PC. 1723 Hamilton Avenue, Suite K 217 Newbridge Road San Jese, California 95125 Hicksville, New York 11801 Stechen Latham, Escuire , Mr. Jay Dunkleberger Twemey, Latham & Snea New Yort State Energy Office Post Office Box 398 Agency Builoing 2 33 West Secono Street Emoire State Plaza Riverhead, New York 11901 Albany, New York 12223 Jonathan D. Feincerg, Escuire Energy Research Grosp, Inc. New York State 400-1 Totten Pond Road Dept'. of Public Service Waltham, Massachusetts 02154 Three Empire State Pla:a
- Albany, New York 12223 Mr. Jeff Smith. .
Shoreham Nuclear Power Station Ezra I. Bialik, Esquire Post Office Box 618 Assistant Attorney General Wading River, New York 11792 Environmental Protection Burtau New York State Department of Law W. Taylor Aewley, !!!, Esquire e 2 World Trade Center Hunton & Williams New York, New York 10047 - Post Office Box 1535 Richmond, Virginia 23212 - Resident Inspector Shoreham NPS, U.S. NRC Ralph Shapiro, Esquire Post Office Box 8 Cammer & Shapiro Rocky Point, New York 11778 9 East 40th Street New York, New York 10016 Herbert H. Brown, Esquire Kirkpatrick, Lockhart, Hill, Mr. Brian McCaffrey Christopher & Phillips Long Island Lighting Ccmpany 1900 M Street, N.W. 175 E. Old Country Road Washington, D.C. 20036 Micksville, New York 11801 Lawrence Coe Lanpher, Escuire Honorable Peter Cohalan Kirkpatrick, Lockhart, Hill, , Suffolk County Executive Christopher & Phillips
. County Executive / Legislative lleg. 1900 M Street, N.W.
veteran's MeccH al Highway Washington, D.C. 20036 Havopauge, New York 11788 Karla J. Letsche, Escuire David Glimartin, Escuire Kirkpatrick, Locknart, Hill, Suffolk County Attorney . Christe:ner & Phillips County Executive / Legislative Sieg. 1900 M S treet, N.W. Veteran's Me',orial Highway Wasnington, D.C. 20036 Havopauge, New Yort 11788 . l m
Shoreham - 2= James !. Dougherty, Esc. 30 5 Porter Street W4shington, D. C. 20005 , Mr. James Rivello Plant lianager . Shoreham Nuclear Power station P. O, los 6?! Wading Aiver,, New York 11792 Lawrence trenner, Esq. Acministrative Judge Atcmic Safety & Licensing Board U. 5. Nuclear Regulatcry Commission Washington, D. C. 20!!5 ' Or. George A. Ferguson School of Engineering Neward University
. .. 2300 - 4th Street, NW .
Washington, D. C. 200!! Dr. Peter A. Morris Ad=ir.f strative Judge Atemfc Safety & Licensing Board U. 5.-Nuc1' ear Regulatory Commission - . Washingten, D. C. 20555 e n D r 4 9 Q h
%e L_. a
4 i
.s .*
A77Etto ::CE List L Sectemee'r 2. 1923 ILE
'. Caruso 4coert J. Giardina -
Charles Petrone J. C. Higgins J. T. Seard -
, D. J. Vito s.}.k2. .
- var. Ostrowski E. J. Ycungling W. J. Museler Kenneth 51mes
. Franklin Research Center R. Clyde Herrick -
Harry W. Raines Shalid Ahmed . - flowsday Stuart Diamond
. K'9.C7
. - Ccunsel fer Suffek County Alan Roy Dynner Stanley Christensen Hunt:n & Williams .
Anthony F. Earley D S e t e k.__
i .
,, .s.
- Enc 1csure 2
'\
Shcreha Nuclea ? ver Statien .. Imerge.cy Diesel Generate: IC: crankshaf: Failure Analysis / Recovery Master Plan t a s 4 Apprevals: {$!l_ ' - \.( j.,t 7:ciec: Enstnee: f[ NW-) . 0..a
, .. . e/ . ' ,.- Q.
7.pe,zaticnal
,s cusaaty Assurance Ing: nee: ..
y hm *
- 3:artugggnagern ,
m_ u l - En a :. .- .a n :.n-' Teat Group _y
. 6 Th nt nanase:
m j #&/ vice 7:esacen;. taucAea: . I O e 9-
. l
- sted: Augas: *:. 1983
- i
1 ! gx 07.zx.ka N": LEAR POWER STA7:CM EXZRGEN0Y C:ZII; : MZ7ATOT. ;;; - grx.y.g.w; n.;;.n nu m E YJ E;D PM 1
- 1. 777.7:3E: ,
j The purpsse of this master plan is te describe the organisation and organizatienal res;=nrikilities !==
, implementing the investigetion into and recovery from the i sgankshaft failure on the 1margency tiesel Generattr 10:
as the Shereha= Nuclear Power Station. This master plan i includes a description of these activities associated with !
- the failure, analysis; the disassembly of the Emergen=y !
- iesel Generater te allew f:: the investigati== =f sne
- . failed es panents: the review of the implications cf this failure en the reliability cf the other two diesel i
, generat=rs #101 and 81:2 and the identification c' reguired ratesting to ensure reliable diesel generater ;
I speration.following repairs. ;(
. t
,It must he emphasized that the master plan is necessarily Ii j!
preliminary in nature. Revisions to the approach will be made, if necessary, as Laformation is chtained during the r actions ses'out in this plan. , i- This master plan has been put in place by the criani:stian described herein, has been reviewed by representatives of L:LO: Project Engineering, L2LCC Startup, the Shcroham i Joint Test Group, Operational Quality Assurance. and tne i Vice-President of Nuclear. In addition, this plan has L been developed with the assistance of TransAmerica DeLaval i Inc. of Oakland, California and Tailure Analysis ' Associates of Palo Alto, California. i I L
- 22. CRGANISATION: !
As a result of the failure of the =rankshaft en , i Emergency Diesel Generator 102, an orgsnisation has j heen put in place consisting et the necessary ; expertise to assess the cause or caus6s of the ; crankshaft failures to recover frem that failure and f l perform determine suitable the retesting followin5.ailure implicatiens of this on dieselrecovery and to t i generators 101 and 103. The essential areas of f
- experstne are shown in Atta=hment Nc. 1 Crgani
- stional [
- nterface Diagram and consist of the ic11 ewing [
- a. Startup Personnel
- 2. Engineering Personnal
- . Scaeduling Fersennel
. f. Vender Representatives (TDI) l 1
f
?
- . +
[ l
1 .
- e. ytan: Staff Maintenance Supp::: Perzennel **
- g. Failure. Analysis 0:nsul:an s
- g. Cpera-icnal Quali y Assurance a..d TD: CA Persen..e'.
In additien to the organisati:n shcun en the attachment, suppcrt from the LILOO Cffice of Nuclear
- as well as -he entire L=ng :sland tighting Ccepanv ars
- available, su h as the Purchasing, Engineering, twin enante Servi es and Quality Assurance Departments. .
A. L:LCO Startur L;;;c startup under the dire::ica cf -he 5:artup
. Manage has the primary line resp:nsibility fe; implenentiny and scheduling the en-tre effs en the
-hree disse. engines since the Emergency Diesel Generaters are still unde: Startup jurisdictica.
Re at: Rework Requests initiated by Tes: Engineers wi.1 he the base documen- fe the rework with Main enan=e Wc:k Requests ( MRP.' s ) heing used to supper administ stive rey:irements of the maintenance con : actor, Catalytic Inc. and other maintenance supper: organizatiens. :=plemen-ing' maintenance
- and test ; ocedures will be generated ha 7:cje: .
Engineering, 5:artup and TD: and will be p;cvided te the field via the ateve base documents.
- 3. 41A22 TE!!ANCE fataly :: Inc., a supplemental main enance c:ntra::c
- to the LILCD Plant Staff maintenance sectica, will prepare the equipmsnt for removal cf diesel genera c:
102 from the Diesel Generato: 7.ccm by disecanetting . the piping, electrical and other appropriate c:nnections to the engine and generate: in acec: dance with Diesel Generate: 1:2 Dis ==nne:-1:n Che h*13: and
. implementing verk reques: documents.
- Gerosa Inc., a 1gging and hauling centracter, will
$ack and skid the diesel engine cut of the room and
, transport the equipment to the Turhine Building
. terrine de:k, Elevation 62'.
Cran A erica DeLaval :nc. (TD:), th6 diesel engine manufacturer, will parier= the disasse.aly and reb 611 ding of the engine. Additionally, the generater will he inspected under the c:gna:ance cf its
.anufa:su:e: 17:: teel se deter =;ne if it sustained any damage. . . 2
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C. LILCD Proice: Incineerine LILCO Pr=.ec Eng:.neer:.ng (LPC) assisted by the S::ne
& Webster Si e Engineering Office (SIO) will prevife engineering supper and is resp:nsible'fer the fai*.ure analvsis. Te acce=plish these tasks L?C will use its cwn 5escurces suppler.ented by Stone & Webster Engineering Corporatien, TO , Failure Analysis
. Asse:istes ane'c her censultant: as recuirec. Failure Analysis Associates has been charged :: take whateve: . . .
, - steps are necessary := cetermine One cause er causes e 4 3 .. . e.
-- ... .w.. a---
r ,. e l Cuality Assurance O. operatzenal Qua11:y Assurance will pr= vide the required Quality Assurance'ecverage in ac=crdance with
. 'the *I*.,CO Quality Assurance Preg :=, TDI CA representatives will be presen: during the peried cf engine disasse=biv and reasse=bly hv. the TOI work = .
derce. The LILCO Quality Assurance De.s.ar =ent will
- -~v ' i n s s ~e~r.~ ~~- .c ".e CW.n ' -c-
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i Startu:mTest Ene.ineeri . l Enc. ineerine. ' Re:resenta tive . TD.I Re.presentativt .. . l D.ilure ' Analys'ig- Associates . hep,resentative C'A' Rep:esentative . . C'
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.respe bleEncinetir f or :,xmple.enting.:ne will .be .- the-Shift Directer.and is activities cesignatec E6 be acce=plish'4d ' du:~i.,g, that shif t. A pre shift
- mek't.ine wil.Ebe held to : insure prcper coverage is .
J.availa.ld
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o and to r.evieu these activities with tne o
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. Cencue an nvestigation of, and develop a detailed failure analysis for the Diesel Genera:Or 102 c _. a ., .s ._.a _ .. __ n_ c e __ ._ ._...a._.._ c_t.ses s
_o_. _aa _a _n ._ __., . .u. _as i e ,__, ,_____ __._.s . _: s s o .e .-
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( w e .n =_ _ a _ _ _- '. ".t d "-_ _' r. ;- * =_ _= _~ ' _- .-. . a . . .d . e _= _e _c. =_ _-._" * . . l 2) Apprcpriate analysis of the failed crankshaft.
- 3) P.eview maintenance and operational history.
C __ .a.._.:. s h _a ,_ ns .__. _4e.. a _= . Cencuct an nspection.and assessment of the adec.uacv. of the existing (13" x 11") anc replacement (13" x 12") TransAmerica DeLaval Crank Shafts for. Diesel Generaters 101, 102 and 103. This effort censists of . J the .o11cwing: . .
. .-eview o, tne Aut _ ces e.n ca2culanzens.
- 2) Performance of independen: calcula icas, as rec Lred.
, 3) Perfer=ance of coeratienal -
tersicnal vibration tests at various scenes anc ene. ne loads en the existing 12" x 11" crankshafts in diesel-generaters 101 and 103 and on the replacement 13" x 12" crankshaft .for i diesel-generator 102. v
- ..,. +m _ _r s
- r_ . G_e. . . r_.:.. . w.., .
. 3_r..
n m.e.r. & _1._e:rC . _ _ Or .s
.A. Inscectiens & Tests - Diesel Generater 102-Tne inspections anc tests on clesel genera c: 102 include but may not be limited to the following:
1.) The cennectine. red for cylinder no. 7 will be
.- pulled to allow for inspection / examination for s _e ._. e , __ 3 _4 ._. ._ _-
_ _ a...a c. e .
.). ."._=' _ .. b e _= _ _3 .- c. = #E, o. , .10 s i. l a _ ida _ _.". . . m_ e 4 . .
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. ..'.e ' e a . _4.- , , '= -
__a _ _' 9 3 s h e '_ '_ .cd - b e _a__m, ' a . =_ . T. .h. _4 = vill be performed as soon as possible te allcw
. ". _= _" "__ a _ ' c .. c .' c = a c. a .
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- 3. Ins:ecticn and Tests - Diesel Generator 101 and 103
. .,. e . . s , ,. .- ..- . .a. s a. ..-
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l- 1.) 100% visual inspectics of cranksnal: wecs and dye y e.e..a...
. .es.s w.he.-. are c... .'a.=.. . . .s' e 1t
. 2.) The c=nnecting reds en cylinder 6 r-s-s-t fil be
=ulled te perfer: 100% LP and *JT of the -
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a -c". a s' .. s rec 'c.s 7 e- -r.c.e "--=. . . . C. Diesel Generator 102 Reverk LILCO nas everall respensamility for the Diesel Generater 102 rework effort. The Startup Test Inc.ineer c= sns_st w:31 .- supervise the varicus aspee:s of the werk c.escr see bea.cw. Catalv. tic cersennel will.. remove ri=.e, tubine'and
.elec:::caA cennect ens, casconnec :ne tur:. cc harger;
.. ~ 5.*. c. e. a.=.. a e d .a. .eea a .d ... "-c-a+.. '. di s c a'.n e c . . . . . .
c, the roc =. anc-sxice ne. t.s.e ene.ine cu m.acxan . Gercsa persenne, w.3, -- r e. a- anc acx une enc.ine, s x a c i t-a.,. d . ,. v. .. -
- ed .,.
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turbine buildine. truck bav.
. The entire ene.ine will be
-_4_s.ed . .#a ~.5.=. .u -b i .. =. b"- ' ' d .4 .7 c. -
c . a.7 e a ..d s e ,. 4 ..s .i d. a. an existine. cac.ed-in area on tne turcine _uus, ne. deck. A clean ... . room will be set up and access control v:... . me estactas ed.
-- -..s-..".e' wili e 'c.- .he d'==sser.b'v.
r . a .w ..c. . l the a=.=r=:riate inse.ections to take slace. The TDI L Service Ree. resentative will be the responsible superviser'for the TDI workman. The generater will also be inse.ected 'er damac.e while en the turbine deck. LILCD and FAA inspections will be perfermed
'c. urine. this worx. .
F Cnce re=cved, the camaced shaft will be sent off site fcr failure analvsis. . 70: perscnnel will rebuile the engine under the s ". .1 .- ~. .' s'c.. c.' a .- S e .- . .' c =. .=.e e . . .c e . . . a . ' v a..' =. .
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. During the investiga:icn of the Diesel Generate 102 failure the~ duly authori:ed Tailure Analysis Asscciate Representative en shift has the a :hority to'stop worn as long as the s:==.
-.cr.,,.
erder does nc: cause a perso.nel safety cencern.
~
' his s:Op wc k authoritation is being _ given to insure tha:
the. Failure Analysis Associa es people are in a p sitic to ansure that they get the ma:cimum inic.sation f =m the f ailure
. a. . .,. e s . _J ; a . _z
. Upon issuing a st=p work order the Tailure-Ana ysis-Asscciate Representative.shall notify the undersigned of this action' e .' a ~ e v. .
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is Enclosure 3 Inf:- .ati:n :.ecuests on Diesel Ge e a : s (D/Gs ! I. General
- 1. Provide a written su.=ary of the approach to be usec on the Failure analysis for DG 102 on an expedited basis.
- 2. Provide the precperational NDE records of the three DG crankshafts.
- 3. Provide the number of crankshaft failures and peculation size for all
~
Delaval D/Gs, all nuclear service Delaval D/Gs, and all R-4 D/Gs.
.provice the failure analysis, if any, for the abcve tranks' haft f ailures.
- 5. Pr: vide the total number ~of operating hours en each D/G and the c al nu=cer of hours at 3900 KW or greater.
- 5. Provide copies of all LILCD/S&W audits of Delaval and responses.
, 7.1 What is the maximum load to which these D/Gs could be upgraded?
7.2 What modifications would be required to make the upgrade? 7.2 What are the limiting components?
.7.4 . Provide an early' reply _as to whether these three c0estions can be answered and an estimate as to when. * '
i
- 8. Provide an explanation of the claim in the June 10, ISE3 letter of Delavai to LILCO that the LILCO DGs are " state of the art" with no other product improvements which could positively affect reliability in light of.the subcover cracks and crankshaft failure and the fact that mooified parts were available but not identified. Also provide a cc.mitment to review all product improvements available for the Shoreham D/Gs, if these D/Gs are to be repaired and used.
. o. Does Delaval have a program where parts /ccmp:nents etc. are modified
-(such as design margins reduced) in order to improve F:6 ,.' . f Does this apply to any D/G parts for Shoreham? / ,
. /'
- 10. Provide responses to all NRC open items on D/Gs.
- 11. Provide responses to all items in NRC consultants's report.
- 12. Provide all vencor decumentation on crankshafts, certifications of conformance, s;ecs, !!DE records, etc. Include statements of how and
-wnere fr:m each crank shaft originated.
~~
~
. - .+
9- ,
\
- 2
- 13. {r:vice j"s-ifjcation fcr grinding cracks c;;- -f 10; DG cr= .ren~a e-
~~~ ~ %
Taiture anasysi! - before any grinding is done. ' 14 Provice a con =ittment for testing to demonstrate adequ'=*'e v"'#3'IC" ~ after reinstallation.
- 15. Res:ense to 5/13/82 Delaval Part 21 report on starting air v>1v. - - -
. asser.oly.
e 9 1 0 0 t i e 9 9 e
,- - . - . , . - - , . _ , . . _ , - _ , . _ . , _ . . , . _ _ , _ , ,_,,,4 , , . _ , , , , , . , , , , , , , . _ _ , , , . , _ , . _ , _ , _ . . , . , _ _ , , _ , , _ _ _ , . _ . , , _ . , _ _ _ _ _ _ _
n *
- 11. Prec:remer.t *
- 1. Provide precurement specifications to which the diesei generators were ordered. In addition, provide the performance specification,' and the inspecticns performed upon receiving the diesels to shew that the procurement specifications were met.
- 2. Discuss all . tests performed on the DG's that were observed by LILCo at the manufacturing facilities. Describe all the tests performed at the manufacturing facilities that were not observed by LILCo. The cescription should include
- test protecures, pertinent ir.strumentation diagrams, and test data and results.
- 13. In acdition to the cualification tests peformec in accorcance with the guicelines RG's 1.g and 1.105 and IEEE Stancarc 557, cescrice all onsite tests that were performed on the DGs. Provide test procedures for these tests and also the data and tests results.
4.- In addition to the deficiency reports alreacy provided to the NRC, describe any installation problems encountered during the installation-and operation of the DGs. Provide complete operating histories of the DGs.
- 5. Provide a 'descripti.on of the original design basis of the straight eignt DGs used at Shoreham and a ecmplete and detailed list of all product icprovements made in this product line of DGs. Include in the descriptien the reccmmended continuous and maximum loads and the operating hours for each rating for each modification.
- 6. Provide a latest copy of the technical instruction manual for these DGs.
D e 4 0
= O '
L
1
,,,. =
at
!!I. Conditier.s of she ~!ile-e Occurance .
".. -{rgvice .e-:Es: prececures -hat were reing usec a ;,,a -i,.g cf n, Eliura.
- 2. Describe tne conditiens in the test area prior to, durine, and after ..e failure. The description should include all certinent test inferma-icr.,
vital signs. and test condi-ions such as test grid conditior., all i..strument reading prior to failure anc post-failure, either, all races, vtbrations noticed and recorded, and noises. i e
- e f
s' , 5 .
./. Failure Investi:ation
- 2. Provice a copy of the Failure Analysis Associates (FAA) cnarter.
- 2. Provide the manufacturer's design calculations for the tersional analysis of the DGs. In addition, provide the models used, metnods of arrivine at the lumped otrameters, justifications of any correlating factors used, calculations of all the natural frequencies, their = ode shapes includine the mode locations.
- 3. ~
Cescribe all the torsional testin; that was perforced by the manufact-urers on the straight-sight DGs. The description should include the test procedure. . test data, test results, configurations and ccmoonents cf the DGs and Icacing devices during the test, and the instrumentation used and their locations. 4 Compare the DGs presently at Shorenam with all either TDI emergency DGs models now in use or to be used in other nuclear generating stations to show that the conditions and/or failure modes present at Shoreham will not occur at these other nuclear plants.
~
- 5. Describe the analytical investigations that FAA is or will be performine
, on the DGs. The description shall include the torsional vibration ~
analysis, the stress analysis and the evaluation of -the TDI torsional vibration and stress analysis. ,
^
~
i-
- 6. Describe all the testing that will be performed by F'AA on the emeggency DGs at'Shoreham. The description shall include test procedures and objectives, instrumentation and location, test data, test results, test loadings, test configuration, power factors, and methods of evaluation load interaction.
- 7. Based on the results of the analytical investigations and the test i results, describe the effects, if any,- that fast starts had on the failure.
E. Describe all the metallurgical and failure analysis of the cranksnaft that will- be performed by FAA.
~
4 9
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- rar.ksnaf /F.efer:ishine cf E_"3's
- 1. ;escribe any new cr additicna'. Orc:lems or d.esigr deficiencies that may c::ur as a result cf the installation of the IEro;2 :rankshaft.
- 2. Describe and justify the requalification testine procram that will ce perfer=ed.on the modified DGs. The descriptien shali. include torsional virration and stress testing, any testing.in addition to the testing required. in RGs 1.9 and 1.108 and IEEE Standard 257.
- l. 2. Describe the impact of the previous multiplicity of failures on the modified DGs. ,
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6 5 , VI Rect-C'ause Analysis
- 1. Previde a rect-cause analysis which shows that the varicus failures dccumented in varicus deficiency reports and other cccumentatiens are ne: causally linked; for examcle yeculd ccclin: water leakace ~
centribute to crankshaft failure? I e l t . . f S S I . I
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, E:::LOSURI 4
,,_ 551NS No.: 6825 IN E2-51
-UNITED STATES
~
NUCLEAR REGULATORY COMMISSION
' OFFICE.0F INSFECTION AND ENFORCEMENT WASHINGTON, D.C. 205E5 August 5., 1983
'IE INFORMATION NOTICE NO. 83-51: DIESEL GENERATOR EVENTS l-Addressees:-
All nuclear power facil.ities holding an operating license (OL) or a construction
- ermit (C?).
Purcose: This information notice is provided to bring to the attention of licensees and construction permit holders some events and experience of generic diesel generator problems and corrective action taken. It is expected that recipients will review the information for applicability to their facilities. No other action or response is required. l Description of Circumstances: I In its continuing r'aview of if censee event reports (LE?.s), NRC has identified i . during the past five months more than 100 LERs pe,rtaining to diesel generator problems . Most of these appear to be material, equipment, or component failures.. No singleocc',mmon trend can be identified. , NRC is_cencerned about the large number of diesel generator events. During discussions with diesel manufacturers and licensees, it appears that many of these events could have been eliminated or prevented by implementation of a conscientious maintenance and inspection program _ as well as monitcring equip-ment through a plant's trend program. Some 1,icensees have instituted such a program to determine the underlying cause of the failures (see IE Information l Notice 82-10) and to prevent their recurrence. Components or materials that have experienced failures are monitored or inspected more frequently. Many - affected items are repaired or replaced before actual breakdown. For example, cooling water heat exchangers that were found to be ineffective after s certain period of time because of tube fouling were replaced. Cooling jacket circulating water pumo bearings are inspected for wear and replaced i.n certain intervals. Pressure switches and timers have' been found with drif ting setpoints and were' recalibrated or replaced frequently.
-Eecause.cf the large number of diesel generator events it is not feasible to
- sscrice til tne events recorted. However, Attachment 1 to this inicrmation I
n:tice gives several representative examples and corrective actions taken. ( , l l e -
. . v., ,.
5 . . .. ..
- n. . :: --.
Augus: 5. 1552 Page 2 cf 2 lf Ac p.e e are any cuestiens regarding :ne Regional r.1strator of the appropriate NRC this Regional r.a::er,Office,
; leaseorcentac: this of ice.
)*A,. I a ^ ~~
Edward L. Jorda , Director. Division of Emergency Preparedness and Engineering Response Office of. Inspection and Enfordement Tecr.niezi
Contact:
'dolfgang Laudan , IE 301 492-9759 . At:acr. ents:
- 1. Selected Examples of Licensee Event Reports Related to Emergency Diesel Generators
- 2. List of Recently Issued IE Infonr.ation Notices G
e G I i L E a e I 6 r--. ---_---f...--- , - - , c,7-_, -- __, -..m--, _., , . - - . - . . - . , - - . , . -
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.c Attachter.t i !
IN 53-51
'ugust 5, 1983 Page 1 cf 4 5 ELECTED EXAMF' ES OF LICENSEE EVENT REPORTS AND YENDOR REPORTS RELATED TO EMERGENCY DIESEL GENERATORS -
OUAJ-C* TIES 2. OCTOBER 5, 1982 . During the monthly preventive maintenance testing of Unit 2 diesel generator, the diesel tripped on high temperature 10 minutes after loading. The cause was determined to be fouling in the cooling water. heat exchancer. The heat exchanger was replaced.and the diesel testing was satisfactorily completed. The licensee placed the heat exchanger on a preventive maintenance schedule, for cleaning,.
'5EOUOYAH 2, OCTOBER 20, 1982 During a performance test of diesel generator 2B-B, the cooling jacket circu'l ating water pump on the diesel generator was found to be inoperable as a result of a . ball bearing failure in the pump. The bearing was replaced and the diesel generator was returned to service. .
SUSOUEHANNA, GCTOSER 27, 1982 ' ( Dur ng a performance test of a d.iesel generator, the diesel generator tripped on high vibration. It was postulated that a vibration switch and a pressure regulator were both involved in the trip. Both were repaired and the diesel
. generator-was returned to service. The equipment will be monitored through L the plant's trend program..
-BRUNSWICK 1, NOVEMBER 5, 1982 l
During a quick start testing program of diesel generator No. 4, the diesel generator tripped on "lcw lube oil pressure." The same problem occurred 2 days later on the same unit. Both events resulted from intermittent failures of the " low lube oil pressure start time relay" (STR). The relay timed out before actual pressure was above the low trip setpoint. The relay was replaced and the diesel testing was satisfactorily completed. . l DRE5 DEN 3, NOVEMBER 9, 1982 During a Unit 3 diesel generator surveillance test, the diesel generator tripped bn low cooling water pressure. A defective' low cooling water pressure switch caused this event. The switch was replaced and the testing was satisfactorily ccm:leted. c;NChC SICO. MAY 25. 19E3 l-During startup testing, the diesel generator would not reach full cpersting speed. The Woooward gevarnor speed adjustmer.t on the unit stepped at about l 650' rpm. It was found that the pointer disk was hanging up behind the cial l -plate. The manufacturer recc= mended filing about 1/15-inch off the pointer disk to allow free movement. After that the diesel achieved proper speed. I o I
v .. r 4 - At achmen- 1 IN E3 . Augus: 5, 1953
- , Page 2 of 4
. CAL'!ERT CL::FS, APRIL 7,1983 Curing'a routine inspection of the intake air check valve of No.11 diesti '
ge trator, the licensee found a check valve holding pin sheared and the check valve locse. The same valve on two other diesel generaters at Calver Cliffs had been found to be cracked when inspected during 1962. The disk of one of
- t.tse .alves was found broken in'two pieces. The engines in ques ion are Fairbanks Morse Medel 38TD81/8.
Because 'these . failures did not render the diesel generators inoperable, as evicenced by successful c:r.:letion of weekly cpera-icnal tests, ne LER was issued. .The licensee pointed out tha: there were internal baffles between the check valves and the diesei turbochar;er which made it unlikely to have a ciece cf tne eneck valve enter the diesel's turoocharger. The eneck valve in questien diver:s air between the diesel turbocharger and integral air-blower. Failure of
' the check valve would result in air being available through the turbocharger at low leads and would affect' the load control.
SHOREHAM. OCTOSER 15. 1982: APRIL 15. 1983: APRIL 20, 1983: MAY a, 1983 L During preoperational testing of Shoreham's three Transa'm erica Delayal, Inc. emergency diesel generators, the folicwing mechanical ~ problems were identified
, :in the cast-9 months and reported by the licensee under 10 CFR 50.55 (e):
' October 15, 1922 - The' jacket waterpump shaft failed.
- April 15,1983 - The engine head cracked. *
-April 20, 1983 - The, fuel injecticn line failed.
May A, 1983 - The rocker arm bolt failed. Approximately' 2 years before these problems occurred, the licensee discovered the_following:
- 1. . Loose hardware in cam gears during initial. onsite inspection.
- 2. P.ultiple broken cylinder head exhaust bolts resulting from insufficien pipe guide clearances in the exhaust manifold.
- 13. . Cracks in the fuel oil ejector that connects to the fuel oil drip line.
~4. Absencelof a drilled passageway for the relief valve on one lube oil pump line as required by design.
- 5. . Leaky lube oil cooler tubes resulting from improper rolling in the tube sheet.
l 6;- l Cracks in rocker arm push rod secket (or cup).
~ 7 .. Cam gear fitted bolts not installed at the factory as required.
L Th6 :recisms were c:rrected under the surveillance of vender representa:ives. _ *iuclear sites witn Transamerica Delavai diesel genera:crs are listed on
; age a of tnis attachment.
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, IN 83-!!
August 5, *.523 Page 2 cf 1 LO"Is ALLIS REPORTED TWO DIFFERENT POTENTIAL PROELEMS. KAY 20, 1953 . e (Louis Allis is the successor tq Belouit Power Systems, Inc. , and to Coit-Fa '. .-banks . Engine Division)
- 1. At the diesel generator in the Clinton huclear Plant, a three-chase rectifier assembly in the exciter was not connected in parallel, which could cause field wir. ding insulation to deteriorate. Louis Allis field service took corrective action by making the necessary connections.
- 2. De roit Ediscn experienced .high vibration on its diesel generator. The cause was loose pole wedces. Louis Allis perferred a detailed engineering evaluatien of this preolem and found that in 19 f a meterial change 'r:n HRS 1020 steel to 1045 steel was made. This means that diesel generators manufactured before this change may experience the same loose pole wedge problem. The affected plants are Fermi, Millstone Unit 2, and Hatch.
These, plants were notified by copy of the Part 21 report dated May 20, 1983. .
' TRANSAMERICA DELAVAL - 1981 TO 1983 , y
, . The manufacturer reported 'the following turbocharger thrust bearing lubrication problem:
-The design of the lubricating oil system permits the oil flow to the turbo-charger bearing only when the diesel generator is running. When the diesel generator is in-the standby mode, the turbocharger bearing lube oil system is bypassed to prevent a possible fire hazard should pressurized oil leak around the ' bearing seals onto hot impellers. Therefore, during startup, a sufficient amount of oil would not be available to adequately lubricate the turbocharger bearing. Because diesels are. started once a month and run for a short length cf time, premature bearing wear was experienced because of insufficient lubrication.
At San Onofre, the wear rate for this condition after 100 hours of operation was equivalent to 15,000 to 20,000 hours of ' continuous operation. To ensure proper lubrication during startup, a design modification in the form cf a lubrication oil drip system causing the lubricating oil to drip on the bearings' through an orifice at a given rate was pro:: sed, installed, and tested. -An alternate method to this design m:dification is a change in the. o:erating procedure. Before a monthly start, an operator would manually run the 'auxiiiary lube oil pumo for 30 to 60 sec:nds and c:nfirm lube oil ressure. In the event of an emergency start, the bearings will function until oil
. pressure is ceveicpad. .
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A a h=en: 1 IN E2-51 Augus: 5, 1953 Dage 4 Of a Transamerica Delaval reported that the following nuclear si es were affected: Shortham , Perry WPP55 4 Grand Gulf Ee11efonte Midland 1 & 2 Catawoa WPPS5 1 Hartsville San Onofre Comanche Peak 1 & 2 Phipps Bend Thelicenseesofth.eaboveplantswerenotifiedby©ofTransamericaDejaval Dar- 21 re: ort dated Septemoer 19, 1950. . 6 l . e W e O O I (- s { i l I . l
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, August 5, 15E3
-LIST OF 8.ECINTLY ISSUED IE INFOXMATION N,0TICE5 Inf or .ation Da e of Nctice No. Suoject Issue Issued to 53-50 Failure of Class 1E Safety . 8/1/83 All power reactor Related Switchgear Circuit facilities holding Breakers to Close on, Demand an OL or CP 83-49 Samoling and Prevention cf 07/25/83 . All power reactor Intrusien of Organic Chemi- facilities holding cals Into Reactor Coolant an OL or CP Systems 83-48 Gaseous Effluent Releases 07/14/83 NRC licensed bypro-of Radioactive Iodine-125 and product material Iodine-131 in Excess of NRC licensees, including Limits medical and academic institutions, radio-pharmaceutical sup-pliers, and indus-trial resear. ch I 83-47 Failure of Hydr'aulic Snubbers 07/12/83 Ali power reactor as a Result of Contaminated facilities hoicing Hydraulic Fluid an OL or CP 83 A6 Common-Mode Valve Failures 07/11/83 All power reactor Degrade Surry's Recirculation facilities holding Spray Subsystem an OL or CP 83-45 Environmental Qualification 07/01/83 All power reactor Test Of General Electric facilities holding Comeany "CR-2940" Position an OL or CP Sel'e ctor Control- Switch -
, 83-44 Potential Damage to Redundant 07/01/83 All power reactor
! Safety Equipment as a Result facilities holding of Backflow Through the an OL or CP Equipment 83-43 Improper Settines of Inter- 05/24/83 All power reactor mediate Range (IR) High faciiities heicing Flux Trip Setooints an OL or CP 53-22 Reacter Mode Switch Modi- 05/23/83 All EWR facilities fica-ions holding an OL or CP CL = 0: erat ng License CP = Construction Permit c ..
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OCT 0 31353 ,'g[' Doccet I;c. 99900334/33-01
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Transamerica Delaval, Incorporated Engine and Compressor Division ATTN: Mr. C. Mathews r Genera 1 Manager 550 25th Avenue Oakiand, California 94251
' Gentlemen:
This refers to the inspection conducted by Mr. J. W. Sutton of this office on July 11-15, 1923, of your facility at Oakland, California, associated with the manufacture of emergency diesel generators and to the discussions of our
, findings .with you and members of your staff at the conclusion of the inspection _
This inspection was made as a result of the issuance of several 10 CFR Parts 21 and 50.55(e) reports. The reports pertained'to: (1) incorrectly identified bolt material, (2) failure of high pressure fuel oil injection lines', (3) failure of jacket water pump shafts, (3) failure of a cranLcase co.'er bolt, (4) unqualified isoprene material, and (5) deficient piston skirts. These conditions were cbserved singly or in combination at one or more nuclear generating stations. Areas examined and our findings are discussed in the enclosed. report. Within tPese areas, the inspection consisted of an examination of procedures and representative records,-interviews with personnel, and observations by the inspector.
*>uring the inspection it was found that the impicmentation of your QA prugram failed to mest certain'NRC requirements. The specific findings and references s to the pertinent requirements are identified in the enclosures to this letter.
1his Notice of Violation is sent to you pursuant to the provisions of
?>ection 206 of the Energy Reorganization Act~of 1974. You are required to f,ubmit to this office within 30 days from the date of this letter, a written statement 'containing: (1) a description of steps that have been or will be c taken to correct these items; (2) a descripticn of steps that havt been er will be taken to prevent recurrence; and (3) the cates your corrective a'ctions and prever.tive 'r.easures were or will be ccepleted. Consideration .zy be.given to extending your response time fer good cause sho n.
Ycu are also requested to s -tmit a similar written stateter.'t fer each item which appears in the enclosed liotice of t;onconformance. l
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1ransamerica Delaval, Incorporated g-l[*,%',",'L'$','"" Engine and Co= presser Division . 2- ,- ..wa' -'av The responses-requested by this letter are not subject to the clearance procedures of the Office of Management and-Budget as required by the Fa;er.ork 3 Reduction Act of 1980, PL 95-511.
- In accordance with 10 CFR 2.790 of the Commission's regulations, a ecpy of this letter and the encle' sed inspection report will be.placed in the NRC's Public Documer. Room. -If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) submit within
- 05. cays f rem the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that 'less than 7 days are available for your review, please notify this
' of fice promptly so that a new due date may be estaD11shed. Consistent with Section 2.790(b)(1), any such application must be acccmpanied by an affidavit executed by'the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted.above, the report will be placed in the Public Decument Ecom.
Should you have any questIions concerning this inspection,- we will be pleased to ' i- discuss them with you. I -
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, nie Vendor Program Branch
Enclosures:
- 1. Appendix A - Notice of Violation
- 2. Appendix B - Notice of Nonconformance
- 2. Appendix C - Inspection Report No. 99900334/S3-03 4 Appencix D - Inspe'ction Data Sheets (11 pages) 4 eo, c n ---a , ,--,,e.-- - ,-,-,--e.-,- e,.,, c , , , , , . , . . .,-- ..,--e ._.-,,,,,,a,e,.-.------+.,--,-,,,.,n. a, ,.m,-- am.m.,-
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APPENDIX A
- e ransamerica Delava's Incorporated Engine anc Compressor Division Docket No. 99900334/S3-01 NOTICEOFh10LATION As a result of the inspection conducted en July 11-15, 1953, and in accorcance cita Section 205 of the Energy Reorganization Act of 1974 and its implementing regulation 10 CFR Part 21, the following violation was identified and has been categorized in accordance with the NRC Enforcement Policy (10 CFR Part 2 Appendix C), 47 FR 9987 (March 9, 1982):
Section 21.21(b)(1) of 10 CFR Part 21, dated December 30,19S2, states, in part: A director or responsible of ficer subject to the regulations of this part or a designated person shall notify the Ccemission when he obtains information reasonably indicating a failure to cenply or a defect affecting . . . a basic component that is within his organization's responsibility and is supplied for a facility or activity within the United States that is subject to the licensing requirements under Parts 30, 40, 50, 60, 61,. 70, 71, or 72 of this chapter. The above notification is not' required if such individual has actual knowledge that the Commission has been adequately informed of such defect or such failure to comply. Contrary to the above, a director, responsible officer, or designated terson had not notified the Commission in regard to:
, 1. Jacket water pump shaf t failures on the emergency diesel generators (EDG) that had been furnished to the Shoreham Nuclear Power Station.
- 2. A potential defect in the fuel injection line tubing that was used on EDGs furnished to Grand Gulf and San Onofre.
This is a Severity Level IV violation (Supplement VII). . e L-
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- Engine and Compressor Division -
- Docket No. 99900334/83-01 NOTICE OF NONCONFORMANCE Eased on t,he results of an NRC inspection concucted on July 11-15, 1983, it appears that certain of your activities were not concucted in accordance with NRC-requirements as indicated below:
Criterion V of Appendix 8'to 10 CFR Part 50 states: " Activities.affecting quality shall be prescribed by documented instructions, procedures, or
- drawings,f of a type appropriate to the circumstances and shall be accceplished in accordance with these instructions, procedures, or drawings. Instructions, -
procedures, or drawings shall include . appropriate quantitative or qualitative '~ acceptance ' criteria for determining that important activities have been satisf actorily accomplished." .
.Nonconformances with these requirements are as follows:
t A. Paragraph 4.6.2 of Section 4 of the Quality Assurance Manual (QAM) dated' L April 30, 1951, states, in part, "when required by Purchase Order material received destined to.become a part of the manufactured item m'ust be
. accompanied by a Certif.icate of Vendor inspection. The material is then inspected to all applicable. specifications utilizing Vendor
, Certifications . . . ." In addition, paragraph 4.1.1 of Quality Control Procedure I.P.200, states, in part, "when it is determined that product
- deviates from specification, an Inspection Repc-t, Form P-249, will be initiated by the Receiving Inspector describing the nature of the defect."
Contrary to the above, the Transamerica Delaval Incorporated (101) - l receiving inspector accepted material on Purchase Order No. 45333, for . which required mill test reports had not been received, without issuing a nonconformance form P-249. - E. Sutparagraphs of II.A and II.B cated January 29, 1976, and Novemper l'O, 1~69, respectively, of the Draf*ing "com Prac* ice (ORP) recuires: i (1) cra ing of layouts on tracing paper; anc (2) a special title block on layout cravings with ample. space for signatures in full of the cesigner l and witnesses along with dates, l ? i l
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Coh'trary to the above, the fellowing lay:. t : asings for the late 19E2 recesign of the emergency diesel generator (EDG) jacket water pump had not been (1) drawn on tracing paper and (2) signed and dated: (a) 1C1571, (b) 03-426-03-AA, and (c) 03-425-10-AE (lined through). , C. Paragraphs 2.2 and 2.3 of the Engineering Operating Procedure (EOP) 4, dated April 19, 1979, states, respectively, The designer shall perform the pecessary cciculations, if required, and prepare the required design layouts. .
"The designer shall sign, date, and submit the calculations which he has checked for ccepleteness and accuracy, alen; with the design layout as required, and his signed and dated form E-213, to the P.anager of Design."
Paragraph II.A.6 dated January 29, 1976, of the 0 rafting Room Practice, states, "Important calculations should.be written in the proper notebook, maintained in the department files." Contrary to the above, regarding calculations for redesign of defective EDG jacket water pumps located at Shoreham Nuclear Power Station:
- 1. Calculations for the first occurrence (1979) which are written in the proper notebook had not been signed and dated in the spaces provided. .
t
- 2. Calculations for the second occurrence (1.932) had not been (a) signed, and (b) written in the proper netebook.
D. Section 6 dated February 27, 1981, of the QAM, contains the following requirements: .s
. 1. Paragraph 6.1.1 state's,'" Documents est'ablishing and defining processes and procedures pertaining to ths quality of the product shall be contro11ec ~by the subdivistog that has the initial responsibility of issue."
~
- 2. Paragraph 6.2.1 states, in part, "All documents relating to the
- quality of the product shall ne riviewed by_the manager of the issuing section or his representativel"
- 3. Paragraph 6.3.14tates, in part, "all cocuments such as Engineering
- drawings . . . reest have a mechanism f orticentification, au,thority of issuance anc revision." ,
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C:ntrary to t$c aseve, "D Sheets" which pertain to cuality of the
=recuct are issuec by the Engineering Department; however, they are not eviewed by.the manager as evidenced by the lack of provisions to
' identify the date, preparer, reviewer, approver, or revision. Examples e are D-4986 and D-4956, which are entitled, " Assembly Instructions," anc pertain to the CDG jacket water pump. It was noted that the latter document reflected the release date, four revision levels and dates in the lower margin of the affected sheets.
E. Paragraphs 5.3.2 and 5.3.3 of Section 5 dated February 27, 1981, of the , QAM, require that Manufacturing Engineering provide written instructions i in the form of rcute sheets', tooling sheets, or special written instructions, etc; . to Manufacturing and Assembly Departments. i Paragraph 16.2.1 of Section 16 dated February 27, 1982, of the QAM states, in part, " Manufacturing and assembly Route Sheets are used as records of in , process inspection of parts, cor ponents, and assemblies. All Route Sheets are retained by Quality Control as objective evidence of inspection acceptance." Contrary to the above, route s'heets for the assembly of the EDG jacket water pump reflected on Drawing No. 101973, Revision C. had not been
. retained by Quality Control at objective evidence of inspection acceptance.
1 F. Paragraphs 2.4.1 and 9.1.1 of Quality Control Inspection Procedure - No.'300 dated April 1, 1981, requires that the area inspector (1) inspect, (2) stamp and.date the Production Routing Sheet (PRS) in the space provided, and (3) stamp an.d date and enter quantity accepted in the final acceptance block of the PRS. Contrary to the above, regarding EDG jacket water pump pa.ts that were manufactured during the time period wher. defective jacket water pumps were being modified:
- 1. Stamp and date had not been entered at Operation No. 90 and final
'. accept block of PRS No. 03-426-08-AE Water Pump Sha.ft which was processed in Detober 1982. Further, the quantity accepted had not ' been entered in the quantity accepted block.
- 2. Stamp had not been entered in'the final accept block of PRS
- No. 101969 Seal Retainer which was processed in Septee:er 1932.
G. Stone and Ve: ster Engineering Corporation Specification Ne. SMI-E9 catec June 24, 1951, provices the bidder with the estion of testing or eyr.amic
.ar.alysis of ever.anical, equipment for seismic cualification.
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Taragra:h 15.3.1 and its subparagra-h 5 of E0P 1 catec A:ril 20, '.9E* , . state that the engine driven jacket water pump will be shake tested. The "Qualificction Statement for 03-425-04 Jacket Water Cooling Pump Revision" dated October 18, 1982, states, in part, "We submit that tnese e changes do not have any negative effect on the seismic qualification of the subject pump . . . ." Contrary to the above, dynamic analysis or testing had not bee'n.conductec on the recesigned EDG jacket water pumps to assure that the seismic qualification had not been compromised. H. Paragraph A.1 of EOP 7 dated April 20, 1981., states, in part, "This pro:edure outlines those steps taken in accc plishing release er revision o' . . . purchase specifications." Purchase specificaticas centain a space for approval. Contrary to the above, Purchased Material Specification No. RL 019000 dated October 6,1982, had not been approved as evidenced by the lack of a signature in the approval block.
- I.
TDI's 10 CFR Part 21 report letter dated June 23, 19E3, concerning a potential problem with the isoprene flexible elements of drive couplings, states,,,in part, "a copy of this letter will be sent to each of the cognizant parties as listed in paragraph 2, no later than July 15, 1982." , Contrary to the above, the TDI notification letters to 10 affected custe.er cognizant parties were cated August 18, 1982. b a 9 s s
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C T.3 ANI Z ATI C!i: 77. A!j$#.[F.!CA DE L AVAL , INCORPORATED i - -- - - s ----eo w :..; tN;.v;t Aao CCw REtScr. O m S:0N u- - . - ~ -~ - _ -0*r9.AND JCALIFCiniA !" - [ ,"*' ; ,; ? L} ,y d i, REPORT -
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. INSEECTION $2-,. fgg; No.- coo 00334/53-01__ -Ot.i E ( t) < _7/11-15/23 ,,,f , 04- 5 ? T E S:
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CCERESF;CENCE ADDRESS: .irantamerica Debval, Incorporatec Engine and Compressor Divisiens '
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~~, 7A11H: Mr. C. Mathews, General Manager '
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Da'd and , _Cali fornia 94261' ORGANIZATIONALCONTA*Th.Mr.;R.,E.Boyer, ^ Manager,.~ Quality Assurance TELE::.CN~_ Ni'[.t E U __ . (a15T 577-74?? ~ s i FRINCIFAL PRODUCI: Ernergentf'diesei-generators.s
- NUCLEAR IN$NITRY ACTIVITY
- T-ansamerica Delavel, Ihcorporated (TDI) has no current cent actssfer domestic nuclear emercency' diesel generators (EDGs).
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ASSIGNED. INSPECTOR: 1. t4 - 9 tth d - 7/.26 /h3 JOW. Sutton, Reactive and Ct mponent Program Oh te <
? Yvectio'n (R& CPS) ,
OTHER INSPECTOR (5): W. E. Fosttr,' R& CPS R.-E.'Oller,' R& CPS . APPROVED BY: . b.- e-7 h ; /! 3 l I. Ea rnes , Chief , R& CPS Date INSPECTICN EASES AND SCOPE: , I A. BASES: 10 CFR Part f.0,' Appendix'B and 10 CFR .Sart 21. B. SCOPE: This ins;.ection was made as a result of the issuance of several j 10 CFR Part 21 and 50.55(e) reports. The reports pertained to: j (1) incorrectly identified bo',t material, (2) failure of high pressure fuel oil injection lines,'(2) failure uf jacket water pump shaf ts, (4) f ailure of a crankcase cover bolt, (ST unqualified isoprene c.aterial, and (5) ceficient piston skirts. Thest cceditions were ebserved singly or in cc.bination at ; l t one or more nuclear h generating stations. I I ( P viT 5 TE APPLICAE!LITY: l incorre:tly icer$ified bol.t material: 50-400. Failure of high pressure fuel ! oil injectien lines: 30-322, 50-206, 50-361, 50-262, 50 416, anc 50-417. l- (cent. :n next psge) s e l l I w
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p.g p 7,- 20N b- - . ~ a b.7 w l NO : 99900334/E3 ~ f ,- - . S ,. PAGE 2 e' :: i l i PLANT SITE APPLICABILITY: (cont.) . Failure of jacket water pump shafts: 50-322. Failure of a crankcase cover
- o.t: 50-415. Unqualified isoprene material: 50-415, 50-417, 50-400, 50-412,
. 50 14, 50-424,-and 50-425. Deficient piston skirt: 50-413, 50-414, 50-518, 50-519, 50-553, 50-554, 50-400, 50-401.
A. VIOLATIONS: .; Centrary to Section 21.21(b)(1) of 10 CFR Part 21 dated Decen:er 30, 1952, a cirector, responsible officer, or designated person had not notified ne Cc::ission in regard to: '
- 1. Jacket water pump shaft failures on EDGs that had been furnished to the Shoreham Nuclear Power Station.
- 2. '
A potential defect in the fuel injection line tubing that was used on EDGs furnished to Grand Gulf and San Onofre. This is a Severity Level IV violation (Supplement VII). l E. NONCONFORMARCES: l 1. Contrary ,tp Criterion V of- Appendix B to 10 CFR Part 50, ! paragraph 4.6.2 of Section 4 of the Quality Assurance Manual (QAM) l and paragraph 4.1.1 of Quality Control Procedure I.P.200, the receiving inspector accepted caterial on Purchase Order (PO) 45333,, for which required mill test reports had not been received, without
- issuing a nonconformance form P-249.
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the ce=mitment date of July 15, 1952, in TDI's 10 CFR Part 21 report dated June 23, 19S2, concerning unqualif'ied material in flexible l drive couplings of EDGs, the notification letters were not sent L '
until August 18, 1982. l l '3. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and subparagraphs II. A and II.B dated January 29, IS76, and November 10,- 1969, respectively, of the Draf ting Room . Practice, the fc11'osing layout drawings for the late 1982 redesign of the.EDG jacket water pump had not been (1) drawn on tracing paper and , l (2) signed and dated: (a) 101973, (b) 03-425-05-AA, and (c) 03-425-10-AE (lined thres;h). Contrary to Criterien V 'of Ap;endix 5 to 10 CFR Part 50, paragrsphs l 2.2 and 2.3 of Engineering Operating Procecure (EOP) 4 cated April 19, 1979, and paragraph II. A.6' dated January 29, 1976, of the l
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PAGE 3 of 14 Drafting Room Practice, regarding calculations for the redesign of ' defective EDG jacket water pumps located at Shoreham Nuclear Power Station: l
- a. Calculations for the'first occurrence (1979), which are written in the proper notebook, had not been signed and dated in the spaces provided. .
- b. Calculat' ions for the second occurrence (1982) had not been
. (a) signed, and (b) written in the proper notebook.
- 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraphs 6.1.1, 6.2.1, and 6.3.1 of Section 6 dated February 27, 1981, of the QAM, "D Sheets" which pertain to quality of the product are issued by the Engineering Department; hewever, they are not
' reviewed by the manager as evidenced by the lack of provisions to identify the date, preparer, reviewer, approver, or revision.
Examples are D-4986 and D-4956 which are entitled, " Assembly Instructions," and pertain to the EDG jacket water pump. It was noted that the latter document reflected the release date, four revision levels, and dates in the lower margin of the affected sheets.
- 6. Contrary to Criterion V of Appendix B to 10 CFR Part' 50 and pa'ragraphs 5.3.2, 5.3.3, and 16.2.1 of Sections 5 and 16, respectively, dated Fecruary 27, 1951, of the QAM, route sheets for the assembly of the EDG jacket water pump reflected on Drawing Ho. 101973, Revision C, had not been retained by Quality Control .as objective evidence of inspection acceptance.
- 7. Contrary to Criterion V of Appendix B to 10 CFR Part 5'O and paragraphs 2.4.1 and 9.1.1 of Quality Control Inspection Procedure l No. 300 dated April 1,1981, regarding EDG jacket water pump parts that were manufactured during the time period when defective jacket water pumps were being modified:
- a. Stamp a,nd'date had not.been entered at Operation No. 90 and i final accept block of PRS No. 03-426-OS-AE water pump shaft which was processed in October 1982. Further, the cuantity l
accepted had not been entered in the Quantity accepted block. i b. Stame had not teen entered in the final accept block cf PRS l No. 101969 seal retainer which was processed in September l i 1SS2. l e
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- 8. ' Contrary to Criterion V of Appendix 8 to 10 CFR Part 50, Stone and ,
Webster Engineering Corporation Specification No. SHI-P.) dated June 24, 1981, paragraph 15.3.1 and its subparagraph 5 of EOP 1 dated April 20, 1981, and the " Qualification Statement. for 03-425-04 Jacket Water Cooling Pump Revision" datec Octeoer 18, 1982, dynamic an'a lysis or testing had not been conducted on the redesigned EDG jacket water. pumps to assure that the, seismic qualification had not been compromised.
- 9. Contrary to Criterion V of Appendix B to 10 CFR Part 50, and pa agraph A.1 of EOP 7 dated April 20, 19*1, Furchased Material Specification No. RL 019000 dated October 6, 1982, had not been approved as evidenced by the lack of a signature in the approval block.
C. UNRESOLVED ITEMS: ,,
. None D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. '(Closed) Nonconformance A (Report No. 32-02):. The Quality Assurance / Quality Control organizational chart had not been updated l
to reflect changes in the QA/QC organization since January 1, 1982. , The NRC inspector reviewed the current QA/QC organizational l chart which was revised on January 15, 1933, showing that the l Nondestructive Examination (NDE) Level.III examiner is no longer the l Panager of Qual.ity Engineering. l
- 2. (Closed) Ncnconformance B (Report No. 82-02)
- Febe Steel Ltd. had I
not been surveyed at a minimum of once every three years as required by paragraph 4.4.3 of Section 4 of the QAM. The NRC inspector reviewed a revision to the QAM, subparagraph 4.4.5, issued April 22, 1933, which indicates that vendors who hold current ASME certificates of authoriztlion or Quality Systems Certificates . need not be surveyed or audited. Chemical ar.alysis of sucject
, crinkshaf t materials were performed and the materials found to, be The NRC inspecter was infor ed by TDI that they intend
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acceptable. to perform a physical inspection at Kobe Steal Ltd. within tne next three months. a I ,,. - - , - , - - . , - , - , ,- ,. --# w. + --e, - - -
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PAGE 5 of 14 1
- 3. -(Closed) Nonconformance C (Report No. 82-02): (a) Component drawings '
released by engineering did not constitute the final instructions to asse=bly for definition of acceptance criteria for the governor lube oil cooler, and (b) instructions for assembly of the governer lube oil coc1cr had not been provided in writing from manufacturing
. engineering to assembly.
The NRC inspector reviewed the lube oil governor assembly drawing and verified 'that the 4ccation of the cooler was not identified. In addition, the parts list for this drawing was reviewed for content.
.The route sheet now indicates the a's-sembly drawing. TDI's corrective action commitments contained in the January 5,1953, letter to the NRC have been complied with.
E. OTHER FINDINGS AND COMMENTS:
- 1. Carolina Power and Light Company's (CPL) 10 CFR Part 50.55(e) notification report, ' dated January 18, 1983, identified that bolting material for the CPL Shearon Harris, Unit 1, EDG was not
, properly identified in accordance with design requirements. 1 The NRC inspector reviewed documents and correspondence between TDI, r- Ebasco, and CPL pertaining to this subject. It appeared'to the NRC i
t inspector that a misunderstanding existed as to whether the bolts and nuts were requested to be fabricated to AISI 4140 or ASTM specifications. The nuts and bolts were bought to the AISI 4140 specification which conforms to ASTM A193 Grade B7 chemical and mechanical property requirements. Specification CAR-SH-E-11, ' 1 Revision 6, did not require ASTM materials to be purchased. TDI's - letter of June 22, 1983, to Ebasco outlines this finding. This is not considered a generic problem. -
- 2. Tennessee Valley Authority (TVA) 10 CFR Part 50.55(e) report to the NRC dated February 10, 1982, addressed the failure of TDI to take corrective action on TVA audit findings described.in TVA audit -
81V' 47, conducted December 1-3, 1981. Documentation and correspondence between TVA and TDI to date was reviewed. Reaudits
, have been performed by TVA to determine compliance to their findings.
TDI had taken action to make sure that preposed corrective actions were implemented before signing of f on the corrective action ' . form. Documentation for compliance to this recuirement was reviewed. All outstanding items we're elesec out by TVA during a TVA resucit. l, TVA's letter to TDI dated August 24, 1932, indicatec no findings. l l' l l
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- 3. Long Island Lighting Company (LILCO) filed a 10 CFR Part 50.55(e) ,
' report on April 20, 1983, with the NRC, Region I. The report stated that f ailures had occurred in fuel oil injection lines to the EDGs that had been furnished to Shoreham tjeclear Power Stat' ion, Unit 1. As a result of the documentation review by the NRC inspector, the following conditions were found to exist:
l
- a. Three diesel generaiors were supplied to the Shoreham Nuclear Station for emerge ~ncy power.
- b. A failure occurred to the high pressure fuel oil injector line during routine testing of Generator No. 102 on March 3, 1983.
The tubing was replaced and on March 5, 1983, a fuel injection line failed on Generator No. 103.
- c. Both lines were sent to an independent laboratory for failure analysis.
- d. A failure analysis issued by TDI dated June 24, 1983, concluded that the failure was at'tributable to the presence of a discontinuity on the inside diamete,r (T.D,),9f the irjection tube.
This discontinuity acted as a stress riser and combined with the line operating pressures resulted in the fatigue endurance limit of the material being exceeded. The repcrt indicated that the discontinuity was a draw seam that had been created during ., manufacture of the tubing.
,e . TDI conducted a 10 CFR Part 21 meeting on June 27, 1983, as required by the Division 10 C(R Policy Procedure, to ev.aluate the findings and to determine reportability to the NRC. The committee determined that this problem was an isolated case and was not reportable. On July 5, 1983, another meeting was held which still determined the condition to be nonreportable due to the fact that many engines had been and are running with the same type of tubing that had been installed at Shoreham.
- f. The NRC inspector requested a search be made as to when the tubing used in the Shoreham Units was purchased and if other nuclear sites could have injection lines installed that had l
been manufactured from the same lot of tubing. . 9
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- g. TDI searched their records and found that the tubing was r purchased in 1976. Purchase lots are made in 2000.ft.
increments with approximately 200 f t. being used per diesel unit. The recced checks indicated that besides the Shoranam nuclear site, EDGs had been furnished to Grand Gulf and San Onofre nuci. ear sites which had utilized tubing from the same purchase lot. ,
- h. TDI Design Spe:ification 0-265 dated October 2,1972, and Revisions A anc 5 dated August 18, 1978,.and August 15, 1920, contain the ap;1icasle recuirerents required to be followed in regard to tubir.; manufacturing operations. The supplier was required to furnish material certificates of conformance a.ad test reports with each o-der. Purchase documentation for this period of time (1975) was not retained by TDI in that the QA
~ program only requires retention for 5 years. The NRC
. inspector revie ed a recent PO for tubing, No. 45333 dated October 1, 1981, for conformance to purchase requirements.
The PO required that mill test reports be furni'shed. A nonconformance, was identified as a r,esult of the acceptance of the material by the receiving inspector, although mill test reports had not been received (see paragraph B.1).
- i. The action to preclude recurrence was contained in the fatiure analysis report, June 24, 1933, and indicated "more rigid QA procedures were called for. Sections from each length of tubing should be cut off, sawed lengthwise at 90? intervais, l
and inspected to ensure there are no draw marks on the tubing l ID. 'Since draw seems ,would run the er. tire length of the tubing, j this inspection measure will ensure that no draw seams are present in any line manuf actured from that length of tubing (200 ft.). Such a QA requirement should be called for on any l high pressure fuel injection line destined for use on a nuclear l stand-by emergency diesel generator."
- j. As a result of the NRC inspector's review of documentation, l . consistency of drawings, procedures, P0s, letters, in-house l
memos, and reperts, it was conc 1'uded that this f ailure may not ! be an isolated occurrence anc that a potential existed.for l draw seams to te present in fuel injection lines of diesil generators se;;1iec to Grand Gulf and San Onofre. In addition, revie of 10'CFR Part 21 evaluation activities
.concerning the fuel oil line f ailure consisted of sice ncies on letters and re:ceds, etc., produced by TDI personnel during Delivered Prod ct Trouble (D.07) meetings.
. These were censidered e-
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as inadequate by the NRC inspector to establish the reason for , classifying this occurrence as one of a kind. The violation detailed in paragraph A was identified as a result of this review.
- k. Subsequent to the inspection, TDI filed a' 10 CFR Part 21-l report with NRC, Headquarters'. The report is dated July 20, 1983, and identifies the following nuclear generating stations with the potential defect: (1) Shoreham, (2) Grand Gulf, and (3) San Onofre.
- 4. LILCO filed a 10 CFR Part 50.55(e) report on October 15,1982, with the NRC, Region I. The report stated that jacket water pump shafts had failed on EDGs that had been furnished to Shoreham Nuclear Power i Station, Unit 1. ' Further, the report stated that the failures occurred on jacket water pumps that had been modified to preclude ,
failures that had been experienced in similar units operating overseas. I 1 The following conditions were observed during the course of the l inspection: l a, The Engine and Compress'or Division of TDI filed a 10 CFR Part 21 report on September 20, 1979, regarding~"a potential failure of l the drive shaft for the engine driven jacket water pump which l would result in engine nonavailability." The report stated that jacket water pumps of the same design as those that failed had been installe'd on the three EDGs that had been furnished to 3 Shoreham Nuclear Power Station. The NRC inspector was informed l that the jacket water pumps had been modified. l
- b. A TDI memo dated October 18, 1982, states, in part, "In the I past five months, Lilco [Long Islane Lighting Company] has ,
experienced three jacket water pump failures." Information ' presented as a record of evaluation was included in open areas of a form entitled, " Authorization For No Charge Billings" dated October 7,1982, and identified LILCD as the customer. The following hand written / printed information was exhibited ' in the open areas: " Review 10 CFR 21 no-only site conditions , at LILCD diff OK other plants not a 30 CFR 21 LILCO unique ' i only site with this preblem attendees (list of names date,d 10-11-82] LILCO is aware of problem TDI & LILCO will solve [ signed, da*.ec 11/11/82)." The infer ation is not sufficiently i cetailed to enable an adequate evaluatien of the decision - regarding reportability. The failure of the jacket water pc.mps had not.been reported to the Cc.tission. As a result of l the foregoing, the violation detailed in paragraph A was l identified. ' 1 l
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- c. Layouts are created by redlining existing drawings rather than r by initiating new drawings. The redlined drawings (layouts) had not been subjected to the required signature /date cycle.
Calculations had not been controlled in the manner specified. There was no indication that assembly instructions had been reviewed / approved. Route sheets for assembly of the jacket water' pump had not been retained; also, some route sheets for manufacturing activity had not been completed as required. The foregoing, along with other observations, resulted in the nonconformances detailed in paragraph B.3 through B.9.
- d. A TDI memo dated July 16, 1579, which addresses jacket water pumps, identifies Gulf States along with LILCO and a foreign customer. Requested documents were not presented regarding Gulf States; as a result, this issue will remain open in order to determine whether or not Gulf States received suspect jacket water pumps. ,
- e. TDI identifies the cause as engineering and assembly induced.
The NRC inspector concurs; however, in his judgement, the l quality organization cannot be excluded. Based upon the observations of this area of the inspection, it is not apparent that adequate corrective actions and preventive l measures have been taken. However, the NRC inspector was informed that the pumps.at Shoreham Nuclear Power Station have operated past the times of the previous failures,
- f. In an effort to assess the effectiveness of the corrective actions and preventive measures, the following areas were -
evaluated: (a) change control, (b) manufacturing process l cor. trol, and (c) records. This area of the inspection was accomplished by evaluating the fo11 ewing documents for requirements and/or implementation.of requirements: 12 drawings, 3 specif'ications, 6 procedures, 3 sections of the QA Manual, 5 memoranda, 7 letters,'and 24 other documents
. identified as: analysis / calculations, packaging / shipping
, notifications, production reuting sheets, qualification statement, material requisitions, auth:rization for no charge billing, failure analysis report, assembly instructions, and -
requests for crafting room action. The findings are indi.cated at other locations of this report. l g. Subsequent to the inspection, TDI filec a 20 CFR Part 21 report dated July 20, 1953, with NRC, Heacquarters. I l h ee - M "M
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REPORT INSPECTION NO.: 99900224/E3-01
- RESULTS: PAGE 10 of 14
- 5. Two 10 CFR Part 50.55(e) reports by Mississippi Power and Light r (MP&L) Company to the NRC were filed on March 22, 1982, and April 21, 1982. These reports concerned the' shorting of the generator by a sheared crankcase capscrew head of a Unit I, Division II, diesel generator furnished by TDI. This matter was reported in several interim reports by MP&L with the most recent one being Interim Report No. 6. .
4
- a. During a 24-hour performance test, the unit tripped on a
" Generator Differential" which was accompanied by electri' cal arcing inside the generator. Later inspection verified that the stator insulation had been damaged and the head from a 5/S x 11 threads x 1 3/4" long capscrew was embedded in the st. tor.
i It was determined that the capscrew head was from the diesel engine's rear crankcase cover. All of the capscrews were i replaced by the utility, and an analysis of the failed capscrew indicated the head br'oke off due to low-stress fatigue cracking during service. This cracking appeared to have been initiated
, by over or under torqueing of the capscrews.
E b. Findines: Review of the problem with TDI's Grand Gulf site service personnel provided the following information: The source of the capscrew head found in the generator stator was ,_ from a top capscrew i.n the vertical crankcase cover. The l screw shank was still in the cover hole. The screws are c'lassed as noncritical service and require torqueing of 60 foot pounds (Ft. Lb.). Since the metallurgical analysjs indicated a fatigue failure mechanism, the cause appears to'
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have been over or undertorqueing coupled with operating stresses. No information was available.to indicate when ghis interrect torqueing may have occurred, TDI service personnel indicated that the site Bechtel craftsman would have had a minimum of two l occasions when they would have removed and replaced the crankcase ! cover for bearing checks after the diesel generator was delivered i to the site. In addition, they would have had a TDI instruction manual which showed the required torque value of 60 Ft. Lb. for i this size bolt while using a special lubricant. The TDI service personnel also indicated that this ine,icent of a sheared screw l-head shorting the generator was a first time occurrence for the TDI diesel generators. The matter was discussed between.TDI anc MP&L personnel, but no meeting notes were cade available to the NSC ir.s;ector by TDI. l
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IN3PECTION ' - - - ' ' ' ^ - I' NO.: 9ee30234/23-01 ' RESULTS: **** ' PACE 11 of 14 6. In 10 CFR Part 50.55(e) reports to the NRC by four electric utility ccmpanies, a misapplication of unqualified isoprene material in the flexible element of the couplings for dies.el generators suppl.ied by TDI was identified. This material was not suitable for use in the high temperature oil atmosphere of the diesel generator and would deteriorate rapidly in service. The couplings were manufactured by Koppers Company. The utilities reporting were: (1) MPLL for Grand Gulf Nuclear'5tation, Units 1 and 2; (2) C:&L for Shearon Harris Nuclear. Power Plant, Unit 1, (3) Duke Power for Catawba Nuclear Statien, Units 1 and 2, and (4) Georgia Po-er for Vogtle Nuclear Plant, Units 1 and 2. This matter was also reported by TDI in 10 CFR Part 21 reports to the NRC on June 23 and July 13, 1982. a. The action necessary to, correct this def-iciency was to change
- out the existing flexible element in the coupling with one made of neoprene which was suitable material for service. TDI, in their report, identified 10 nuclear power plants which have affected diesel generators, and indicated these cognizant par. ties would be notified no later than July 15, 1982.
- b. Findines: The NRC inspector verified the following information through observations, discussions, and review of documents:
(1) The incident which prompted TDI to report on June 23, 1982, was a failure of a coupling flexible element made of isoprene in a nonnuclear diesel generator. The i utilities reported subsequent to the above date. The suspect couplings were manufactured by Koppers Company starting in 1977 and purchased as stock items by TDI based on TOI's purchased material specification for
" Couplings-Elastomeric, Part No. AK-007-000," cated November 11, 1976. The original version of this specification did not specify the type material of the flexible element. After the above failure, TDI issued l .
Revisions A, B, and C to the specification in 1981, 1982, and 1981,. respectively. Change A specified that the flexible element should be nec;rene which is a suitable
- materi'a1. Change B specified service in a 175'F* oil
! atmosphere, and Change C specified that the flexible element must have a 1/2 " wide red band on it to 1 cistinguish it as neoprene.
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F.EPORT INSPECTION - n ,J .'." .". - - - ' NO.: 99900334/81 01 - RESULTS: 1 r i nve' L / UV PAGE 12 e< 14 (2) Review of TDI notification letters verified that all r nuclear order customers with affected diesel generators - were notified of the deficiency. However, 10 of the TDI notification letters were dated August 18, 1982. This date was contrary to the TDI commitment date of July 15, 1982, in their 10 CFR Part 21 report and re'sulted in the nonconformance identified in paragraph B.2. (3) Observation of a ccupling flexible element in the stores capartment verified that it did not have a red band on it as required by Revision C of the purchase specification. However, this flexible element ~was identified only by part nu=ber and it could not be traced to specific P0s placed with Koppers Company after April 25, 1983. , (4) Review of receiving inspection cards, " Vendor Inspection Report," for Koppers Company, indicated that the bases for receiving inspection of the couplings was Mil-Std 105 D.
' (5) Review of 10 CFR Part 21 evaluation records concerning the isoprene flexible element established that' records were inadeouate to establish the cause of the misapplication and the basis for the determination that the item was reportable under 10 CFR Part 21. The only records available were entries dated June 15 and June 22, ISS2, in the DPT committee weekly log. The June 15, 1982, entry indicated Product Engineering was to compile a list of engines using Kopper's Elastomer GDV drive couplings, l
and the June 22, 1982, entry indicated that it was determined that the Kopper's Elastomeric coupling was a 10 CFR Part 21 reportable item and the responsible individuals were to issue the appropriate notification. l These DPT committee meeting notes did not provide .
' sufficient information to show the bases for the evaluation (and do not appear to meet the requirements 10 CFR Part 21, paragraph 21.51(a) and (b)).
- 7. In five 2.3 CFR Part 50.55(e) reports to the NRC by three electric
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utility ecmpanies, a deficiency in the piston skirt castings of diesel generators was icentified. This matter concerned the* potential failure of the engine piston skirt castirgs of diesel generators'su; plied by TDI. Such failures would result in the unavailability of the diesel generators. The castings were l manufactured by TDI tetween December 1975 and October 19S1. ! The. utilities reporting were: (1) Duke Po-or for the Catawba Nuclear Station, Units 1 and 2; (2) TVA for Hartsville
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REPORT INSPECTION No.: 559; I24/S3-01 RESULTS: PAGE 13 of 14 i Nuclear Plant, Units 1 and 2, and Phipps Bend Nuclear Plant, Units 1 and 2; and (3) CP&L for the Sheator. Harris Nuclear Power Plan , Units 1 and 2. This matter was also report'ed by TDI in a 10 CFR Part 21 report to the NRC on October 28, 19S2. The NRC inspector ascertai,ned'the following information by discussions and review of doruments: .
- a. The incident which prompted TDI to recort was a f ailure of a type "-AN" piston skirt casting in early 1930. The utilities subsecuently made their reports to NRC. Subseouently, TDI procuced a report entitled, " Failure Analysis Nc.152, Piston S ki rt , P/N 03-041-02-AN," cated June 20, 1933. This report included a description of events leading up to a change in foundry heat treating practice to include f an cooling of *he castings. This cooling method was determined to have resulted in high residual stresses in the castings which, when combined with operating stresses, could result in failure of the castings. The report also provided recommended correctivt measures including HDE, stress relieving at 1050*F, and selective grinding of the affected castings.
- b. Review of six TDI notification letters verified that all utility nuclear units with affected diesel generators were
, accounted for. The letters included a list of foundry shop order numbers'and serial numbers of the affected castings to aid the utilities in identifying the suspect castings. The letters also recommended that the castings be returned to TDI for HDE and. stress relieving if possible, or replacement with suitable castings, and return for reinsta11ation. As of this inspection date, only Duke Power Company and Gulf States Utilities have returned. skirt castings to TDI.
- c. Review of a current process routing for Job No. 69501 covering reprocessing of returned castings verified that corrective action was being performed under controlled conditions using
. process travelers, qualified personnel, and procedures. Other records reviewed for Job Ho. 69501 consisted of: (a) special instruction specification No. 750R; (b) a certificate of ccmpliance; (c) a packaging and shipping notification; (d) a magnetic particle inspectien report; (e) an NDE technician's cualification record; and (f) heat treatment receres for Iron ASTM A-536, Grade 100/70/03 cas-ings. The review also
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O'RGANIZAT!cN: TRANS A".E RI C A DE LAVAL , INCORPORATED ' 'yl,i.~,,".. -' . . ' r, .,*4~. ,;.~ 3 gT,". ENGINE AND COMPRESSOR DIVISION l_... ... . . . '._: OAKLAND, CALIFORNIA P ' V M .' T i " --- n '-. .'.
- v*vi n REFORT INSPECTION v s , , s. i 6.s av ~
NO.: 59900334/S3-01
- RESULTS:
PAGE 14 of 14 included the original mas'ter engine book of records for ' diesel generator 5.N. 75018-2762. Within this area cf the inspection, no nonconformances or unresolved items were i d.e nti fi ed. F. EXIT INTERVIEW: , During the exit interview, at which time the inspection findings were discussed, the NRC inspectors were informed by TDI's management that they wobid take exception to all of the violations that had been icentified during the inspection. The NRC inspector incicated that this position.would be identified in the inspection report. It was determined by staff review subsequent to the inspeci. ion to defer issue of one violation which had been identified to TDI management until after
, performance of further inspectio'n. This violation suoject pertained to inadequate evaluation records. -
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ATTACmiENT 8
Delaval Diesel Generatne Ooeration Exoerience U. S. Nuclear Exoerience In 1974, the Long Island Lighting Company (LILCo) contracted with TDI to purchase three emergency diesel generators for the Shoreham Nuclear Power Station. This was the first order received by TDI to provide an EDG for a comercial nuclear power station. In the next seven years, engines for 14 other plants were ordered from TDI. San Onofre 1 Two TDI Diesel Engines Installed in 1976 - DSRV-20 Serial Nc. 75041/42, Rated at 6000KW (nominal) 8800KW (peak) , Engine Run Time to Date - 450 hours per engine The first plant to actually place a TDI engine into nuclear service was San , Onofre Unit 1 (SONGS 1), which purchased two V-20 units to provide emergency power for its feed pumps, which also serve as Emergency Core Cooling System pumps. , The enoines at SONGS 1 were installed in 1976, and declared operational in April 1977. Since then, SONGS has experienced some problems with the '
. operation of the engine turbochargers, a lube oil pressure sensing line
, failure which resulted in a fire, and several other minor problems. Because l SONGS did not commit to meet the guidelines of Regulatory Guide 1.108, but rather Regulatory Guide 1.9, the program it used to test the engines before '
they were placed in service was more abbreviated than for a new plant. A l detailed list of problems to date follows. Date - Problem Cause/ Solution 12/80 Excessive Turbocharger No lube oil during standby. thrust bearing wear. Lube oil system modified. 10 CFR Part 21 report issued because problem generic. 7/81 Lube oil leak and fire. Excessive vibration of a lube oil test line which had inadvertently been left , installed by the licensee. ( Line removed. 12/81 Piston modification to Pistons reworked by TDI to
, prevent crown separation. respond to Part 21 report.
Problem identified at Grand Gulf. . 9/83 Unqualified instrument . Replaced in accordance with , l cable. Part 21 report. l l . .
I
- 2. - ,
Grand Gulf , _. Two TDI engines installed - Model DSRV-16 Serial No. 74033/34, Rated at 7000KW Operating Hours to Date , Division I = 1100 hours; Division II = 700 hours In 1981, Mississippi Power & Light (MP&L) commenced pre-operational testing of two V-36 engines installed at Grand Gulf Unit 1. They represent the first V-16 units ordered from TDI, and in fact, one of the Grand Gulf engines was used to qualify the entire TDI V-16 line of machines for nuclear applications. The Grand Gulf engines have experienced significant problems in completing the pre-operational test program, have had several major failures, including a fuel line break which caused a fire, and many minor failures. A detailed list of problers at Grand Gulf follows. Date Problem Cause/ Solution 11/81 Piston crown separation during Holddown studs failed. operation. Pistons returned to TDI for rework. Generic problem. 3/81 Excessive turbocharger thrust No lube oil during standby. - bearing wear. Lube oil system modified. 6/11/82 Air starting valve capscrews Response to Part 21 report, replaced. Too long for holes. 8/23/82 Flexible drive coupling material Replaced with different incompatible with operating material. environment. , 8/82 Latching relay failed during Relay replaced. testing. 3/8/82 Air start sensing line not Sensing line relocated and , seismically supported, properly supported. , 1/29/82 Governor lube oil cooler Lube oil cooler relocated to located too high. Possibility lower elevation.
. of trapping air in system.
3/23/82 Engine pneumatic logic Pneumatic logic design improperly design. Could corrected. result in premature engine shutdown. e
l i
,0,11g . Problem Cause/ Solution
. 4/29/81 ion-Class 1EmotorssJpplied Motors replaced with Class IE vith EDG auxiliary system qualified motors.
pumps. ,. 3/15/82 Crankeese cover caps' crew Capscrews replaced with
-. failed. Need lodged in higher strength screws.
generator and shorted it out. Lock tab washers installed.
,~ -
Generator screens installed. 8/h83,' . /High pres'sure' fuel injection Manufacturing defect in line failed. tubing. Tubing replaced.
- p. , ,
9/4/83 Fuel oil line failed. Caused High cycle fatigue of y- , . / , major fire. Swagelock fitting. Additional
'I .
tubing supports to be installed.
'v~_ , . , ,
j- 8/11/83 tracksl ni contiecting push All push rods replaced.
,g yed welds. ,,
1983 V Turbochargervibrati5n. Turbocharger replaced.
^' ' -o e 1983 Cracked ' Jacket > water welds. Excessive turbocharger vibration. Cracks re-welded. .
1983 '
. Turbocharger mouriting bolt Excessive turbocharger failures. vibration. Solts. replaced.
7/83 .
/ Air 1tartvalvefailures. ~ Cause unknown. System cleaned
, and several valves replaced.
- More frequent maintenance
. scheduled.
. 10/28/53 - F[eb'Ji1 lead.~ Tubing replaced.
- Crt:ket push rod weld. ~ Push rod replaced.
. During EDC- - Cylinder head cracks. Head replaced.
. Installation en
/.
' Two heads replaced.
12/83 . Cylinder head cracks. , ' 12/83 Cracks in. piston skirts All Division !! pistons on Division !! EDG. replaced. Divis' ion ! pistons to be inspected. l f/83 Unqualif ted instrument cable. ' Replaced in response to Part 21 report, j
. 4 l .
g I ns~
D . Three TDI Diesel Engines installed. Model DSR-48 Serial No. 74010-12 Rated at 3500KW Operating hours at time of crankshaft failure (8/83)
#101 = 646 cracked crankshaft)
- #102 = 718
- #103 = 818 failed crankshaft))
cracked crankshaft The engines at Shoreham are the first straight-8 units to be placed in nuclear service in the U. 5. One of the Shoreham engines (#101) was used to qualify the straight-4 series (R48) diesel engine for nuclear service. Pre-operational testing of the engines at shoreham started in late 1981 and continued until the major failure of the #102 crankshaft on August 12. 1983. After the performance of extensive tests in late September and early October, which were observed by staff members from NRR and Region I, as well as an NRC consultant, LILCo presented the results of its crankshaft failure investigation in a meeting on November 3, 1983. It reported that the
- crankshaft had been improperly designed, and had failed because the loading function used in the original design calculations was too small. LILCo also
. reported that it was investigating four failed connecting rod bearings which
.were discovered when the EDGs were disassembled. Their preliminary finding was that the fail'eres occurred because the bearing material did not meet specifications, and' the bearing loads had not been roperly accounted for. ~
A detailed 1,ist of the EDG problems at Shoreham fol ows. jgg, Problem Cause/ Solution 3/81 Eacessive turbocharger thrust No lube oil during, standby. bearing wear. Lube oil system modified. 12/81 Piston modifications ,to prevent Pistons reworked by TDI to crown separation. respond to Part 21 report. Problem identified at Grand Gulf. g/82 Engine jacket water pump Water pumps reworked by TDI. modifications.
- 8/82 Air starting valve capscrews Response to Part 21 report.
replaced. Too long for holes.
'9/82 Engine jacket water pump shaft Pump shafts redesigned and failed by fatigue, replaced. ,
Spring /1983 Cracks in engine cylinder heads. Fabrication flaws. All heads replaced. ' 4 S
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Date Problem , .Cause/ Solution 3/83 Two fuel oil injection lines Manufacturing defect in ruptured, tubing. Tubing replaced with shi.elded design. 3/83 EngineLrocker arm shaft bolt High stress cycle fatigue. failure. ' ' Boits replaced with new
- design.
8/1'2/83 Broken crankshaft.. Cracks in Inadequate design. Replaced remaining crankshafts'.' with larger diameter crankshafts.
- =
9/83 Cracked cor;necting rod bearings. Inadequate design and
' ' ~ ~
. _ substandard material.
. . Replaceo with new design.
10/83 Cracked piston skirts.'. ' Replaced all piston skirts with new design. Generic r' -
- - . problem, 11/8$
Bro (encylinferhEadstudnuts. Replaced all head stud nuts.
# Cracked bedpl'ates- in area of-9/83 . Cracks evaluated by LILCo and I main journal bearingc. . ' determined to not be
? - '
. significant.
Replaced in response to 9/83 - ' Unqualified instrement cable. s, . Part 21 report.
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-.n.- r - , , _- , ---- , ,,- - - - - , - - - - - - - - - ~ , , , .
r Operatino Experience - Non-Nuclear Marine Applications ' Besides being used for stationary electric power generation, TDI diesel
, engines have been placed in service as propulsion units on commercial carge
, vessels. As part of the Shoreham operating license hearing, an intervenor, Suffolk County, requested and was granted by the Licensing Board, subpoenas for the State of Alaska, U. S. Steel, and Titan Navigation, Inc. These three organizations operate vessels whi,ch use TDI V-16 diesel engines which are very similar to most of the TDI units installed in nuclear power plants. The responses which were received . indicate that the TDI engines in marine service
, for these organizations have experienced severe reliability problems. Most
, have related to faulty cylinder heads, but they have also included problems with pistons, cylinder liners, turbochargers, cylinder blocks, connecting rods, connecting rod bearings, main journal bearings, and camshafts. A detailed. experience list follows. The staff is reviewing this material to see how much of it is applicable to engines in nuclear service.
9
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e j* . l i ( l
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L.
e o 0 Marine Excerience with TDI Diesel Generators
- State of Alaska, M. V. Columbia Vessel fitted with two DMRV-16-4 Engines - Serial No. 72033/34 Rated at 9200 HP (6900 KW) at 450 RPM Vessel and engines placed.in service in June 1974.
Each engine has approximately 30,000 hours of operating time to date. Docurent Date Problem Description 12/76 All cylinder liner seals replaced. All
, cylinder heads have been removed, reinstalled, or renewed at least three times.
All pistons have been removed and
. reinstal. led at least once.
Turbochargers have been removed, repaired and reinstalled, or renewed 16 times due rotor to leaking damage, or oil seals,beari,ng defective vibration,l sea housing. Exhaust manifolds have been removed and reinstalled because of frozen expansion j joints and resulting cylinder head flange face damage. Lube oil consumption is excessive. 6/15/78 Rapid deteriorations of fire seal rings
. causing blowby across gasket surface of cylinder heads.
i Very low lube oil filter life (40 hours). [ Caused by blowby of pistons and valve guides. Stainless steel exhaust bellows burn out rapidly. Installed backwards by TDI. l 11/28/78 '(Letter to Alaska from TDI). , Recommends timing changes to improve '
- j. turbocharger performance. ,
!' -___..__-._____.__,...u___ _ _ _ _.-.., _ ... _ ,._ ,_ _ _ _ . , _ - . . - . _ _
A
.s 8-Document Date Problem Description . .
1/31/79 Valve seats and valve guides not concentric. Results in bad valve contact. Defective piston rings shipped as replacement parts. P.eworked cylinder head received from TDI l , without all required modifications and , l with damaged gasket face. Newly furnished cylinder liners received with incorrect surface finish (twice). Connecting rod bearings furnished as spare parts were wrong size - 13" vice 12". Turbocharger exhaust flex section incorrectly furnished by TDI. ' 2/2/79 Chrome plating failure of piston rings. Caused heavy scoring of cylinder liner. Associated cylinder head'found cracked. Seven cylinder heads replaced during 15 weeks of operation. Excessive lube oil filter change out rate. Due to piston blowby. Fuel injector spray tips changed at TDI recommendation to reduce carbon buildup
. and eliminate washing of liner wa.lls with fuel oil.
Three major overhauls of engines in 5 years of operation. Carbon accumulations in rocker box areas. l Excessive oil vapor discharge from engine crankcases.
- Heavy carbon deposits on valve springs.
I Suspect valve blowby. , When exhaust valve guides were modified by TDI, they did not follow the procedure
- outlined in their SIM (Service Information Memo).
l l S
Document Date Problem Description Loose piston pin end caps. Incorrect piston crown to skirt bolt torque. Bad connecting rod bearings. Excessive wear, cracks. Damaged connecting rod bolts. Valve push rods cracked at weld of ball to pipe. QC problem. Crankshaft size changed after engines for ship installe.d. No notice to owners of reason for change. Excessive main bearing wear. Camshaft lobe hard facing worn. TDI recommended the installation of a new . flexible exhaust duct which was too short (new design). Installation attempted at
~
insistence of TDI. Unit damaged by attempt and returned to TDI for repair. 3/19/79 QC or material problems with respect to non-concentricity /out-of-round valve seats, push rods, rod bolts, bearing shells, valve stem plating. 6/14/79 Thermal growth and cracking of exhaust manifold, l l 12/26/79 Failure of new connecting bearings. Cracks of 25% of connecting rods. l l . l 4
? - - - . . - , , .,-.------.,---.,---nm . , - - - , - - - - . . - - . ,
r Document Date- Problem Description 1/16/8b Ten (10) new cylinder heads have cracks. This includes 8 that were previously repaired. Fifteen (15) valves are defective with chrome flaking off the valve stems. Valve. stems are being defonned. Five additional push rods have cracks.
, Turbocharger air cooler inlet housing is cracked for fourth time.
Internal bracing in engine intercoolers is cracked. 2/5/80 Piston rings installed improperly because
.. mistake by TDI-in the drawing used by TDI shop.
2/29/80 - Piston crown-to-skirt nut torque inconsistent among nuts on various pistons. Excessive link rod bushing bail wear caused by improperly relieved, dril' led oil l passages on the matching -link rod pins.
- . 3/24/80 Abnormal carbon deposits and formations noted on pistons and cylinder head
. assemblies.
Fretting of jaw areas of connecting rods. Insufficient turbo '(manifold) air except at near full speed operation. Cracked. exhaust manifold end plates. '- i' Cracking of connecting rod boxes.
- Cracking of newly installed connecting rod bearing shells at 4500/ hours.
L . l
- - . . ~ _ _ .._ _.. ... ,_ .-_.__._ - ..-, _ _ __.. _ _ _ ..- - . _.___ . _ _ _ _ _
Document Date Problem Description,, Fretting of link rod and link rod pins at their attachment together. Fretting between link rod bushings and* link rod bushing bore. Galling of link rod bushings in way of t link rod pin outer drilled. oil passages. Improper wear / contact pattern on newly installed connecting rod bearings at 4500/ hours . Four-point loading. Insufficient connecting rod bearing wear / contact area to journal wherein it is less than 15% of the total bearing area. Upsetting of stems in valve keeper area. Damage to number four piston ring end ring groove on all pistons modified during the 1978-79 engine teardown and rebuilt after 4500/ hours operation. Fretting between piston crown and skirts at 4500/ hours since piston modifications. Variations in piston bolt torque, beyond specified limits, at 4500/ hours since piston modifications. Damage to rod bolts, including cracking, and damage to threads on both the bolt and in the rod boxes. 1 4/18/80 Exhaust manifold conversion kits received I with cuts and grooves in finished ' surface. Required rework by owner before installation. 5/12/80- rods received without New connecting required code (American Bureau of Shipping)
. approval. TDI did not have record of which l
- . rods were shipped with approval,or without l
approval. Some new connecting rods shipped with - oversize bearings but no note to customer informing of_ difference. l
, , ,, - , . , . , ,,.n ., .., . . - . , , - . , - , - - ,,.,-,,m ,,w.--, ,
Document Date Problem Description 5/14/80 Cylinder head returned to TDI has been lost by TDI. Cannot be located. 5/15/80 Customer received new connecting rod bolt in rusty condition with damaged threads. 5/27/80 Customer received reworked cylinder heads
- with lip left on exhaust seats which prevents valves' from seating. -
Customer noted that it now was in possession of two cylinder heads with the same serial number. Could not install lockwire in new connecting rod cap screw. Hole drilled partway through with drill broken off in center of hole. Also noted that edges of
, lockwire holes on other screws had not been rounoad to prevent damage to lockwire. ,
5/29/80 Discovered leaks in newly installed
. exhaust manifold head plates.
9/4/80 (Meeting Summary) TDI says that all cylinder head problems should be corrected by new design. TDI reports that connecting rod bearing cracks could have resulted from bad bearing alloy makeup by vendors. TDI [ looking at different bearing materials. TDI stated that they had erred on piston modifications. Effected others besides COLUMBIA. 9/30/80 Eleven remaining master connecting rods to be sent to TDI to have oversize bearings and other modifications installed. l' Ma'ny of the original cylinder heads that were returned to TDI for rework were exchanged for other used heads. t 4
- l'3 -
Document Date Problem Descriotion - 11/6/80 Cylinder head changed due to heavy external water leakage. Severe smoke causing excessive lube oil
, contamination and engine room atmosphere problems. Engine secured to prevent possible crankcase explosion.
112/10/80 All connecting rods removed. New rod cap l ' screws and washers to be installed because increased torque specified by TDI caused galling. New connecting rod be'aring shell found cracked. Heavy wear noted on piston side thrust areas. Heavy Sard carbon buildup noted in area of compression rings. Fourth ring groove area to be 5ework~de by TDI due to design / machine error by TDI during previous modifications. - Ninetaen (19) of 32 cylinder liners exceed spec for out-of-round. TDI to modify limits to permit continued usage. Twenty-one (21) of 32 liners lost crush. l- , New phenomena. Repairs require machining i of. engine block. , Fuel injectors removed and to be changed t-from 140* spray pattern to 135' pattern. Original nozzles had 150' pattern. l- [. 1/16/81 Cylinder block bores found to be distorted. Four new engine camshafts installed.
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1 G 6 e e
M _ Document Date Problem Descriotion 3/13/81 Reworked cylinder heads were returned to the customer without removing the grinding compound from the valves and valve seats. Two reworked pistons returned to customer without roll pins, which lock the securing nuts in place. Cylinder liner delivered with wrong surface finish. Cracks found in cylinder blocks. All replaced. Main engine blocks found to be cracked and warped. The main block-to-base through bolts appear to have been improperly torqued during initial assembly.
~
One "new" camshaft found to be a rebuilt unit containing several damaged bearing journal areas. The threaded head stud holes in' the new cylinder blocks were not counterbored deeper, as TDI had indicated they currently do. This was to eliminate cracking of the block near the stud
' holes. The customer re-machined each of the 256 head studs to accomplish the same
~ intent.
l 4/9/81 Several reworked pistons were returned without groove pins. In response to a request for 20 li" . capscrews and washers, TDI supplied 1 7/8" capscrews. ' i Drawings furnished by TDI for head stud modifications were not applicable to the studs in que.stion. 50% of the fuel pump bases would not fit - onto the new cylinder blocks be'cause of ' slight changes in the design of the blocks. I
<w.
Document Date . Problem Description Two new cylinder liners provided with incorrect surface finish. One new cylinder liner provided with flange thickness larger than
, manufacturer's maximum tolerance.
New connecting rod capscrews were found to be galled and unfit for use. . 4/29/81 Service manual showed incorrec. installation of engine camshafts. 2/3 of fuel cam tappet assemblies on one engine could not be installed on one engine because the new cylinder blocks had not been properly counterbored.
~
Cylinder liner counterbore depths were off to such an extent that difficulty j experienced in establishing proper liner crush. . Weld spatter noted on many seating surfaces. Dirt, sand, and metal showings found in passages and holes which should have been clean. Cylinder head water port outlet locations
- varied considerably, causing a water flow restriction.
i Air start distributor not properly assembled at factory.
. 6/1/81 Exhaust manifold head plate developed a leak. Cracks found around 2 of 3 tie rods due to poor initial welding.
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11/19/81 Defective valve springs found on one - engine. 7/29/82 Valve rotator failed. l Cracks discovered in the intercooler. l l - I i .
l l Document Date Problem Description 7/29/82 -
"In nine years of operation every basic l
engine component has been modified or replaced with an improved item, at least once, with the exception of the crankshaft - (which is obsolete and has not been used
, for years), the engine base, the fuel pumps and the governor. The last two items are not manufactored by TDI."
l 10/15/82 Turbochargers' replaced.
- Exhaust valve lubricating system to be installed.
3/9/83 Cracks discovered in three cylinder heads. Reworked cylinder returned to customer with tap broken off in threaded hole. Others returned with internal cracks and l' damaged flange faces. O i S 9 l- { l
Titan Navigation, M. V. Pride of Texas Vessel fitted with two DMRY-12-4 engines, Serial No. unknown Rated at 7800 HP at 450 RPM Engines installed 1981 - no information on total engine hours to date. Document Date Problem Descriotion 7/16/82 ' Catastrophic pisten failure. Due to crack
- in piston skirt. Engine had 5791 hours of operation.
4/1/82 Cylinder block broken and cracked. Cylinder head cracked. Cylinder liner cracked. Piston skirt fractured. Suspect that all of above problems caused by water leaking into cylinder from air intake manifold. Leaking tubes found in Lir intercooler. 8/19'/82 Cracks discovered in six piston skirts. 7/22/82 Cracked exhaust valve seats in cylinder ! , heads. Engine had 3000 hours service. , Camshaft lobe design appears to.be l deficient. Causes excess'ive stress on fuel cam lobe and roller. Tappet assembly rollers severely galled. Believed to be due to camshaft and lobe placement and inadequate heat treatment. I Fuel cam lobes have failed twice due to i
- improper heat treatment. '
I Chrome plating lost from one piston wrist I pin. All four intercoolers have failed because l of erosion due to high fluid ve,locity. Air start valves have suddenly ceased to ( function, for no apparent reason. f
1 Document Date . Problem Descriotion Plugs in crankshaft oil ways may be - cracking because improper material used. Under investigation. Fuel oil return lines have failed. To be replaced with heavi.er wall tubing. 4/1/83 Exhaust valves fail after about 2000 hours of use. Serious problems with cylinder head cracks. Turbochargers experiencing difficulty supplying sufficient air. 6 6 , t O t e t 9 I
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U. S. Steel, MV E. H. Gott Vessel fitted with two DMRV engines (model unknown) Engine Serial No. 75039-40 ho information on engine hours to date. Document Date Problem Descriotion 11/13/80 Cracked cylinder head. Replaced. 11/1/79 Cracked cylinder head. Replaced. 6/,1/80 Cracked cylinder head. Replaced. 10/8/81 Cracked cylinder head. Replaced. Note: This information was summarized from documents provided by U. S. Steel in response to a subpoena which asked specifically for information about cyliner head failures. Many other portions of the documents were deleted by U. S. Steel, and it appears that the deleted portions i referred to problems with other engine, parts. i i 4 l . l l 4 4 S t
Other Aoplications The staff understands that other TDI engines are in service as stationary electric power generators. The. operating history of these engines will be taken into consideration during the staff assessment of TDI engines. O e G t e 0 e 4 1 O F 1
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4 i e O e l l I d
Reference List Shorham _ _ _ Letter dated 1/6/84 from B. McCaffrey (LILCo) to H. Denton (NRC) Board Notification 83-160 dated 10/21/83 Board Notification 83-160 dated 11/17/83 Letter dated 12/9/83 from J.' Smith (LILCo) to T. Muley (NRC) Letter dated 12/9/83 from A. Schwencer (NRC) to M. Pollock (LILCo).
' Letter dated 12/29/83 from A. Schwnccr (NRC) to M. Pollock (LILCo) .
Letter dated 12/16/83 from C. Matthews (TDI) to T. Novak (NRC).
' Letter dated 12/16/83 f, rom J. Smith (LILCo) to T. Murley (NRC)
Letter dated 12/16/83 from A. Dynner (Suffolk County) to A. Earley (LILCo) Letter dated 10/20/83 frotr A. Earley (LILCo) to L. Brenner (NRC) Letter dated 10/16/83 fror. R. Boyer (TDI) to NRC , Letter dated 11/17/83 from A. Earley (LILCo) to L. Brenner (NRC) ' IE Infomation Notice 83-51, dated 8/5/83 IE Inspection Report 99900334/83-01, dated 10/3/83 IE Information Notice 83-58, dated 8/30/83 Grand Gulf - Letter dated 11/15/83.from L. Dale (MP&L) to H. Denton (NRC) l Letter dated 10/19/83 from L. Dale (MP&L) to H. Denton.(NRC) - ( LER'50-416/83-171/03L-0 dated 11/28/83 Letter dated 10/26/83 from L. Dale (MP&L) to H. Denton (NRC) LER 50-416/83-082/01T-0 LER 50-416/83-126/01T-0 l -
E . 22 - 4 San Onofre Unit 1 LER 50-206/81-017 dated 8/12/81 Letter dated 9/15/81 from.H. Ray (SCE) to R. Engelken (NRC) LER 50-206/80-039 dated-12/23/80 l Letter dated 6/8/81 from J. Haynes (SCE) to R. Engelken (NRC) Marine Aeolications . Letter dated 12/21/83 from A. Dynner (Suffolk County) to A. Earley (LILCo) Includes many.other individual documents. l . . l 6 9 I.
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O I !~ l l L_
V S b ATTACHMENT 9 i- ~ ' J N ?' 1 i. k. s
_ Vendor InsDection History To date, the Region IV Vendor Inspection program has inspected the TDI
. facility in Oakland, California, nine times. The following inspection reports have been published in the POR regarding these inspections:
- 1. Docket No. 99900334/79-1, dated 3/20/79 .
- 2. Docket No. 99900334/80-01, dated 1/22/81
- 3. Docket No. 99900334/81-01, dated 5/27/81
- 4. Docket No. 99900334/81-02, dated 9/18/81 -
- 5. Docket No. 99900334/82-01, dated 4/15/82
- 6. Docket No. 99900334/82-02, cated 12/8/82
'7. Docket No. 99900334/83-01, dated 10/3/83
' Attached is a summary by the Vendor Inspection Branch of the TDI inspection
. history. The history includes some results from the last two inspections, which are being reviewed for proprietary information, and which will be published when that review is complete.
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ATTACHf1ENT .s l TRANSAMERICA DELAVAL INSPECTION HISTORY ' VENDOR PROGRAM BRANCH FINDINGS 1979-1983 MANUFACTURING PROCESS CONTROL: ._
- 1. Performance of required inspections for completed operations on Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment could not ce verified, in that neithe'r inspection acceptance stamps were present on the route sheets 'for the completed operations nor were inspection reports available.to indicate rejectable conditions had been found upon inspection. ,
- 2. Route shee'.i were not available to confirm required inspection acceptance of. assembly operations for the emergency diesel generator (EDG) jacket water pump reflected on Drawing No. 101973, Revision C. .
. 3. Absence of evidence of inspection acceptance for co'mponents manufactursd during jacket water pump modifications performed in September and October 1982.
- 4. a. Acceptance signoff by QC. inspectors was made on route sheets in-regard'to installation of rocker arm hold down bolts. These bolts
/ *4 were subsequently found to be missing on inspection at the Shoreham Nuclear Power Station (SNPS).
- b. ShipmentofreworkedpistonstoSanbnofre, Unit 1,priortodates
- indicated on route sheets by QC inspectors that various manufacturing operations were accepted.
- 5. a. Route sheett not issued for rework of 92 pistons from SNPS and Grand Gulf EDGs and there is, thus, no evidence of inspection acceptance of the various manufacturing operations.
- b. No records of quality activities for rework activities on Grand Gulf EDG pistons which was a specific requirement of the procurement specification.
- 6. Absence of required NDE reports for SNPS replacement cylinder head castings.
i 7. . Apparent use of unqualified personnel for performance of NDE operations on SNPS replacement cylinder head assemblies.
- 8. . Improper signoffs and dates for acceptance of SNPS replacement cylinder heads with respect to personnel identity and use of a surrendered inspection stamp prior to expiration of the minimum 6-month phriod.
- 9.
- Use of a different hard facing welding . procedure specification to that specified on the route sheets for valve seats in SNPS replacement cylinder head assemblies.
i .10 . Requirements not provided for welding of and acceptance of Shearon Harris l- EDG fuel oil line clamps. l L . i
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- 11. Prior to October 1981, manufacture of piston skirt castings did not comply with engineering component drawing instructions with respect to performance of specified stress relief heat treatment.
- 12. Route shee s for Job No. 02933 did not provide instructions in regard to swaging operations performed on crankshaft oil plugs.
- 13. No assembly route sheets available for SNPS replacement cylinder head assemblies.
. CONTROL OF SPECIAL PROCESSES:
- 1. Absence of procedures _for examination of Level III NDE personnel and failure to qualify personnel performing visual examinations in accordance with ASME Code requirements.
'2. a'. Performance of vertical up position welding on ASME Section III piping (Shop Engine No. 2931, Shop Order No. 94302) by welder qualified only for flat position weldin'g. , ~
- b. Welding of a 2'-inch ASME-Section III piping assembly by unqualified welder. -
- 3. Observations during three different inspections of failure to return unused welding electrodes in required 4-hour issuance period.
- 4. Identification of welders used for certain operations on Shop Engine Nos. 2931 and 2959 could not be verified.
- 5. Unacceptable fillet weld size in Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment due to bad fitup'of tank roof and sidewall resulting in ,
almost. flush condition. .
- 6. Use of welding electrode sizes that were not permitted by applicable welding procedure specifications on Job Nos. 94922 and 96632.
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- 7. .Use of Job No. 95395 of welding amperage and voltage in excess of welding
[ procedure specification requirements.
. 8. Performance of welding on Job Order No. 97-4'85-3085 without specified revision of welding procedure specification being in welder's possession.
'9. Certification records for nondestructive examination persenrei did not F. 3 indicate the use of ten checkpoints by the examiner during the practical
- examination as required by SNT-TC-1A and internal pescedures.
. PROCUREMENT CONTROL:
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- 1. Failure of Quality Engineering to both update Qualified Suppliers List every 3 months and to provide a monthly summary of vendor quality ratings to QC and Purchasing.
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; 1 '2. Evidence not available to assure that the seller of auxiliary lube oil and jacket water pump motors complied with the requirements of the purchase order.
l 3. Betts Spring Company, a supplier of critical valve springs, had not been surveyed every 3 years. The,available evidence showed it was approximately 5 years since a survey had been made. - , 4. Associated Spring Company (Barnes Group) was placed on the Approved Suppliers List and used for procurement without completion of a survey or audit. ~
- 5. Kobe Steel Ltd. . a supplier of crankshaft, was not surveyed every 3 years as : required by the quality assurance program. ,The only available record was a self
- evaluation survey . form completed by Kobe Steel's American representative.
- 6. Fuel' oil tubing for Purchase Order No. 45333 was accepted'by receiving inspection without. issue of a nonconformance report, although required mill test reports had not been received.
- 7. Purchased Material Specification No. RL 019000 dated October 6, 1982, was not approved as . required by Engineering Operating Procedure 7.
- 8. A OA program was not imposed on the manufacturer of exhaust silencers for EDGs furnished to Perry, Units 1 and 2, as required by Perry Specification Nos. SP-750-4549-00 and SP-706-4549-00. *
! 9. _ Purchased material specifications for engine mounted electrical control
-cables required only commercial grades of cable and did not invoke i
applicable customer specification requirements.
- 10. a. No available evidence to indicate that materials which were used to fabricate EDG ASME Section III Code Class 3 component supports (Midland)dr's from vend who were either identified on the Approved Suppliersand List or had been subject to audits.
b, prior to 1982, ASME Section III Code fasteners were procured from
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vendors who had neither been audited nor were identified on the A9 proved Suppliers List as being approved for supply of this product.
- 11. Acceptance by receiving inspection of ASME Section III Ccde fastener
. certifications which did not comply with purchase order requirements with respect to: .(a) conformance of chemical composition te material specification requirements, (b) completeness of mechanical test data, and (c) compliance with ASME Section III Code reouirements for reporting of material heat treatment.
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- 12. Failure to comply with testing requirements of oaragraph NCA-3867.4(e) in the ASME Section III Code when purchas1ng stock materials from unsurveyec vendors.
MATERIAL IDENTITY AND CONTROL: . Eleven discrepanc'ies in material identity observed in a sample of 45 between the identity of material issued and that recorded as being used for Midland EDG S/N 77002 piping system component supports. DESIGN AND DOCUMENT CONTROL:
- 1. Failure to comply with Division Standard Practice Nos. 4.101 and 4.201 requirements with respect to:
, a. Release of a drawing revision to the shop without receiving approval of the applicable Engineering Change Notice from Industrial Engineering. .
- b. Maintenance of the Engineering Change Log, classification of changes as major or minor, and initiation of required forms.
'2. Parts list and component drawings released by Engineering did not define l
acceptance criteria for installation of crankshaf t oil plugs. l
- 3. Absence of any instructions' in regard to instalkation location of governor
[ , lube oil cooler to engine. - 4 Failure to comply with Drafting Room Practice'during 1982 redesign of the EDG jacket water pump in regard to ce'rtain layout drawings no't being either drawn on tracing paper or signed and dated.
- 5. Dynamic analysis or testing not performed in accord.ance with Stone &
Webster-Specification No. SHI-89,after redesign of the SNPS EDG jacket water pumps.
- 6. Failure to comply with Engineering Dperating Procedure 4 and Drafting Room Practice requirements with respect to signing ahd dating of calculations by the designer for the SNPS jacket water pump redesign.
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- 7. No evidence of required approval of "O Sheets" by the applicable
!f - Engineering manager. Examples-noted were D-4986 and 0-4956 wnich were entitled, " Assembly Instru;tions," and pertained te the EDG js:tst water pump.
- 8. Jacket water pump analyses dated September 24 and October 4, 19S2. and July IS, 1983, for SNPS had not received required certification from the staff Registered Professional Engineer.
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NONCONFORMANCES AND CORRECTIVE ACTION: 1.- .No evidence to indicate that required quarterly submittal of completed 3 corrective action activity to the Division General Manager had ever been accomplished. -
- 2. Failure of Quality Engineering to process a required Corrective Action Request Form af ter customer identification of TDI failure to meet wele quality requirements in ASME Section III Code Class 3 diesel generator ~
piping. -
- 3. a. Removal and replacement of a defective weld in Shop Enginer No. 2931, Part No. 02-717-02YR, without required rejection and documentation on an-Inspection Report. ,
- b. Disposition of a dimensional nonconformance on Shop Engine No. 2931, Part No. 02-540-07-87, ma'de by QC supervision without required submission of the Inspection Report to the Material Review Board for review.
14 Failure to comply with ASME QA Manual requirements with respect to immediate identification of nonconforming items, on Inspection Reports and
. segregation of the items. -
- 5. Weld shop audit not per. formed in the fall oY 1981' in accordance with corrective action commitments made to the NRC. . ,.
EQUIPMENT CALIBRATION:
- 1. Actual calibration measurements for micrometers and a pressure gage were '
not recorded as required by Quality Control Procedure No. IP-100.
- 2. Gage used to measure, accept / reject the diameter and depth of the link rod dowel counterbore had not been identified in accordance with QA program requirements for calibration equipment.
3. Measures were not established to assure that tools used in crankshaft oil plug installation were properly controlled and adjusted at specified periods to maintain accuracy within necessary limits.
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4 a. A welding machine'in Weld Area No. 3 (Foundry) was observed in September 1983 to hav'e calibration stickers showing a calibration due date of August 30, 1980. The 0A program calibrati:n frecuency requirement for this equipment is 12 months. , b. A heat treat furnace was observed in September 1983 to have l calibration stickers on the meters and temperature recorder snowing a \ calibration due date of March 13, 1983. E' L . L ,
- 1
, i l
. INTERNAL AUDITS: -
Failure to perform required semiannual audits of the Foundry, Manufacturing and support a'ctivities. 10 CFR PART 21 PRACTICES:
- 1. [ Records were not ava,ilable with respect to' fractured thermostatic control valves in Grand Gulf, Unit 1, EDGs to indicate either that an evaluation had been conducted in accordance with 10 CFR Part 21 recuirements or snat actions had been taken-to determin,e whether the product deviation contributing to the valve fractures (i .e. , improper use of raised face
. flanges in connecting piping) was'present in eQuipn. ant supplieo to other customers.-
- 2. Notification to affected parties 'in regard to.a potential problem with
' isoprene flexible elements of drive couplings was made after the committed date in the 10 CFR Part 21 report.
.- 3. Failure to notify the NRC in regard to:
' a. Jacket water pump shaft failures at SNPS. .
- b. Potential' defect in' fuel injection line tubing that was used on'EDGs furnished to Grand Guld and San Onofre, Unit 1. -
OA RECORDS: -
- 1. Records not available to demonstrate environibntal qualification of
- auxiliary lube oil and jacket water pump motors with respect.to Bechtel Specification Nos. 9645-M-018.0 and 9645-G-QA-1.
-2.. Failure to prote'et records against fire in accordance with QA Manual requirements noted during two separate inspections.
' MISCELLANEOUS:
Failure to have Certificate of Compliance for SNPS replacement cylinder head assemblies' notarized in accordance with customer , specification requirements. 6
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'TRANSAMB.ICA DELAVAL, INCORPORATED c- VENDOR PROGRAM h$ANCH. INSPECTION HISTORY
SUMMARY
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OF NINE !s5PECT10NS O'JRING 1979-1983 ~
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., , Number of Sub.ieet ,
Nonconformances/ Violations Manufacturing Proce'ss Cohcrol 13 Control ef.Special Processes 11 Procurement. Control 12
. , . Material Ioentity and Control 1 Design and Document Controi 8 Nonconformances and Corrective Action . 5 i Equipment Calfbration' . 4 Inter.1a'l Audits .
I 9 10 CFR Part 21 Practices' 3 (Violations) QA R'ecords' 3 Miscellaneaus 1 B w Y
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3 ATTACHMENT 10 u$
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'1 , _ , % '+ ', . . UNITED STATES OF AMERICA *
-NUCLEAR REGULATORY COMMISSION 2 .
s s w < 2 4 1 c'* l-5 , 6 s s ' 7 8 8 - A Meeting on TDI DIESEL GENERATORS r 4 - 10 i i 11 g ' 12 !
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i 13 . , - r', Pnillip[. Building'
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Bethesda,- Maryland 15 ' , Thursday, January 26, 1984 m . 16 '- - s 17 i 18 i,I ,
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19 ' ;
> s-A meeting on TDI Diesel Generators convened 1.s g 20 .j at 5:'04 p'. 3. , Harold Denton presided.
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j-2 .! I I APPEARANCES: ' 2 . i t 3 ( Attendance List will be Generated.) - 4 i l l I 5 i 6 I 7 8 e 9 , 10 11 12 13 14 '
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I 15 l 16 17 i - 18 l 19 20 l 21 l . 24 ! , 25
3 ! s 1 MR. DENTON: Good' afternoon. My name is
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2 Harold Denton. What we are going to discuss today is l 3 the results of the staff review of the reliability of 4 the Delaval diesel, i
- 8 We started looking. int' e nsively in this area f
i 6 when problems began to develop at San Onofre, Grand Gulf, , 7 and at Shoreham. Since that time, our review has ex-i a panded. 9 We are prepared today to discuss with you in I 10 detail the results of all the information that has come 11 to our attention regarding the operating performance of 12 these diesels. - I i 13 We also have with us today the Regional Ad-14 ministrator from Region IV, John Collins, who conducts l 15 our vendor inspection program. He will describe the 16 results of his vendor inspections at the f actory of 17 Delaval Diesels. 18 i I understand that the owner's Groue has 19 been informed of the utilities who own these diesels, L . 20 and they are represented today by. Jim :tcGaughy, who is 21 the Chairman of the Owner's Group. I understand that L n ! the Chief Executive of Delaval Diesel Corporation is i 23 , also present, and that his representatives will be 24 making a presentation. l 25 Let me discuss a few ground rules to ':egin f l
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l 1, with, to make the meeting go smoother. We are taking a 2 transcript of this meeting. The issue is in contention, 1 3
.as you know, at several proceedings. And this makes it I 4
easier for us to provide the Hearing Boards a complete l i 5 1 and accurate record of what information is made available f 6 today. Because of this transcript, it's'very important 1 i 7 that anyone who has questions or comments be sure to 8 identify themselves for ,the record when they ask questions. t 9 Tne way I would like to walk through this cro-
. 10 I l
cess is to have the staff first describe in some de- l 11 !
. ' tail the information that has become available in the .
. 12 last few months on the performance of these diesels in .
13 the field. This is mainly at nuclear power plants, but 14 we also colleeped data from some non-nuclear sources. , 15 l hen, we will cover the vendor inspection, as 16 I mentioned. . Then, we turn the meeting over to the 17 utility. Owner's Group, .tho I understand is prepared to is describe their remedial program to try to establish the i is reliability of these diesels. 20 I understand, Jim, that peu may have an Open-21 ing -- openi,ng' remarks to say before we begin. Xhy fon't n i you do that now? . 23 ;ta, .icGAUGHY: Good a'fternoon. My name is 24 ! Jim'McGaughy. I am Vice-President of Mississippi Power. 25
.and Light Company. I am speaking to you today as Chal man l
1 9.
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I 1 i of the Delaval Diesel Owner s Group. 1 I 2 The issues that will be presented here, we 3 ~ feel' the problems that have been found in our pre-opera 4 testing program and our subsequent research and reported 5 to the NRC, , as they've been found, 'using the proper pre-6 scribed methods. i For some time, all the owner's of these i 7 ' engines have bound together putting the best minds avail-8 t able in the world on these issues in the one effortto '
'9 I study and correct these issues. i 1
10 Our goals and the goals of the NRC are the 11 - s ame . . We are' committed to provide our plant to reliable 12 emergency backup power supplies. We feel this comprehen-13 sive program we.have in place, in place now, working now, i 14, l will do just that. 15 We are here today to tell you about what it 16 is that we have been doing. The elements of our program
- 17. j are four. The
! first element -is resolve the known problems,,
18 both. generic problers and problems in the specific engines i 19
. themselves ,
l i to design and find fixes to these problems. ! 15 i
'In addition, we will take -- and are in the
- 21 process of taking each engine from the ground un, review-22 ,
ing its design, its construction, its procureg.ent and 23 f doing a quality revalidation on each and every engine. 24 From the results of the quality revalidation, then we 25 go into testing, and the testing involves non-destructive J
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i 6 1 testing, destructive testing, operational testing of, 2 components, operational testing of the engines. This 3 work is in progress now. 4 And also then we will, through this group, 5 respond to the questions, of course, that the NRC will 6 put to us. The participants in our program are as j 7 follows. We have the eleven owners, and I will have a I a list of those for you later. Eleven utilities. l FaAA
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9 Associates, who are renown si doing f ailure analysis work . j 10 We have the wholehearted support of Delaval in this i tit e f fort, l
. ~ both in gathering of information and gathering i 12 of design data, and in review of this data. Stone and !
13 . I Webster Engineering is supporting this effort. And also i 14 several diesel generator consultants from around the 15 world, h 16 The organization the Owner's Group has set up I 17 i
! has me as Chairman, Mr. Joe George of Texas Utilities as 18 Vice-Chairman. Executive Committee made up of the eleven L i 19 utilities.
i I The Technical Director of' the program is Mr. l 20 ,j Bill Museler of LILCO.
! We have taken :ne program that
- 21 l LILCO has started on their site, adding to it.
- i The work 22
! is 'being done at the LILCO site.
1 2'3 . { As you see, in resolving the known failures and 24 ; determining solutions to those problems, FaAA is takin: 25 i the lead; that is their speciality. In terms of design I mw--.w -m,w-r-e w - - - - -,,-,--%--- y--w-----rm---w. , - - - - - , -=,.-+<-.-,,----~---g- --c, , .
7 ' i s i l 1 I i review and quality revalidation, we have FaAA, Stone and l l 2 Webster, our various consultations, and we have engineers 3 from each utility working in this effort. The testing 4 i program definition and carrying out the tes, ting program 5 will be donc, of course, by the utilities who own the 6 f engines and operate them, and' by FaAA who will assist us 7 in that e f fort. 8~ To aive you an idea of the extent of this pro- ) 9 i gram, I would like to put this chart up. This is the i 10 organization enat is in place. We have over a hundred and ; 11 twenty peopic full-time working on this effort, working on u this effort now. This is in progress. We are confident is that.when we complete-this program, that we,will have 14 reliable enoines to provide backup power supplies for these 15 pl ants . 16 Thank you. . 17 , MR. DENTON. As those of you know, who own is these diesels, this is a very important safety issue for l , 19 the NRC. There are about fifty-seven engines made by (. 20 Transamer.ca Delaval that are in this, owned by the six-21 teen utilt:tes that are on our list. None of the Delaval - I 22 diesels are it operating plants, which eans it's not an 23 i 1 imminent s if^:y . problem today, but certainly it '.as pre-I 24 i found i.mnl .catiens for schedules for some of the utilities 3 if the proclom is not adequately addressed. I i l
B l 1 1 l I did want to mention my perspective on the
.t safety side to be sure it's well unders,tood. The only 3
plants that are operating that have Delaval diesels are 4 San Onofre Unit 1. That plan,t is shut down for a seismic
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5 modification. Grand Gulf, which is limited to a five - l s percent power license and is presently shut down. And, i 7 Rancho Seco, which is using other diesels, but I under- , 3 stand has ' ordered, or has in place, several Delaval diesels l l g which they have intended to install. ' to We view this as a verv serious problem for the 11 ' industry. It is unique to have a problem in what I will ' 12 call a' convention component of American technology. You l 13 ' wouldn' t think that diesel generators would get on the l 14 critical path of the nuclear power reactors, but that's 15 very ,likely wnat has happened'. .
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16 And just so there is no doubt about where the 17 i
- staff stands on this issue, we are not prepared to go 13 forth and recommend the issuance of new licenses on any 19 - !
plant that has Delaval diesels until the issues that are
. 2 raised here today are adequately addressed. It so unds 21 like we have a very ambitious program. What I want to do 22 ' is make sure you have all the information we have.
2 And if we come to an understanding about the i 24 l ' factual basis that we - are working with, so we can move < 2 I to a discussion of the information-we have been able to L l l- ! b , 1 l e - - - ,
9 i I gather, and if everyone would hold their questions to the , 2 extent they can, we can get through the presentations 3 faster. 4 We will provide ample opportunity for discus-5
-sion after we have gotten the factual basis. on the table.
g Then, we will turn to a detailed presentation of your l 7 program. And I plan to provide it break somewhere in the f g meeting. -But we will probably go until about six o' clock. I l 3 The first presentation will be made by Frank go Miraglia and assisted by Carl Berlinger. Carl Berlinger 11 is a Senior Manager on the NRC. staff. We designated him
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as the person respo'nsible for ultimately reviewing your ' 13 program and making sure that it is an acceptable, adequate [- . 34 program. 33 So, Frank, why don't I turn over to you to
- 16 cover what we know 'about the operating experience.
17 MR. MIRAGLIA: My name is Frank Miraglia. I
- to am the Assistant Director of the Safety Assessment Divisicm 19 ' of Licensing.
20 The first view graph is a list -- the first 21 view graph indicates the fif ty-seven Delaval diesels that 22 have been procured for use at sixteen different nuclear i l 23 power plan
- sites.
- - l May I have the second view graph?
24
.We are going to discuss the U.S. experience 25 ! with these diesels in the operating stations to date.
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10 t i The next slide is a brief summary of the operat-2 ing experience with San Onofre 1 station. The informa-3 tion en this view graph is in a very summarized fashion. 4 We have a more detailed handout that will be available 5 at the end of the meeting that has additional details 6 1 about the operating experience and chronology with some j 7 of these machines at the various nuclear power stations. ! 8 There are two Delaval diesels at San onofre 1. 9 They were installed in 1976. They are Delaval V-20 l 10 engines. They were declared operational in 1977. The ! 11 l' operating time on each engine at San Onofre is approximate-. u ly 450 hours. 'These .are actually the first Delaval diesels: to enter nuclear service. 1 13 14 Problens to date are indicated. on the slide. . 15 They've had turbocharger thrust bearing problems. This ! tis event resulted in a Part 21 report, was issued and pro-17. blem was considered to be of a generic nature. 18 : They've had a lube oil leak and fire, which 19 was a result of a fuel line failure, test line of f a labe 20 oil line which failed because of vibration. And it was a 21 small fire. I 22 The pistons have been . modified at San Onofre 1 23 to correct a problem that is noted at Grand Gulf and 24 - , i resulted in a Part 21 notification there, to prevent crown l 25 . ; separation. l k l
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11 l' They've had an unqualified instrument cable, 2 ' which also was replaced in conformance with reported 3 Part 21 occurrence. And just recently in another Part 21 report, there is potentially defective coupling material. 5 That Part 21 report was filed earlier this month. 6 The next slide is a suamary of the experience . 7
,on - the -- of the Grand Gulf diesels. They have Delaval 8
diesels. They are the V-16. The operational hours on I i 9-the diesels are 1100 hours on the Division I diesels , i 10 and seven hundred hours on the Division II diesels. ' 11 These are the first V-16 Delaval diesels to Et enter nuclear service. The problems to date are the -- 13 Number one is the pistol crown separation. That was a ' 14 generic problem and identified this particular problen 15 as a Part 21 for the Delaval diesels. 16 They have experienced piston skirt cracks, 17 ; and piston skirts have been replaced on the Division II 18 diesels. 19 They've had a fuel line failure, which resulted 20 t in a fire. And the fuel line f ailure was due to fatique , 21 They have experienced cylinder head cracking on these tt. ; diesels. The heads have been replaced. t n . t In addition to those, they've had the turbe-I l 24 : charger problems . I believe three different ins tances of 2 ' turbocharger problems. And, again, you can.see commenalitJ 9 o i 6 .
n - - . 12 1 between this experience 'and 'the San Onofre experience. 2 They have experienced push rod cracking pro-3 bloms. In addition, they've had the generator short due 4 to an engine fastener. This was a crankcase capscrew 5 failed and had Lodged in the generator and shorted the 15 generator out. 7 in addition, Grand Gulf has also experienced a problems w;tn their air starting valves which has resulted ! l 9 in failure of the generators to start. 10 , This summarizes the experience with the San 11 Onofre and the Grand Gulf units. I would like to have U Ralph Caruso summarize for you the experience to date . 13 on the Shorenam machines and also to present a brie'f 14 i summary of the information that we have been able to i 15 gather f rom -non-nuclear marine experience with similar 16 type diescis. . 17 Ralph Caruso. l 13 , 1R. CARUSO: The engines installed at Shoreham g 19 are ::odel OS R-4 8, straight-8 engines. They are rated a: n m 3500_kilc.atts and e.e-e-approximately 700 hours rcughly 21 on each enaine at the time o f' a major f ailur'e o f crank-22 shaft in ' Au=us t o f 19 8 3. ' I 23- i Those engines were the first straight-3 engines 24 i to be inst.1Llod in the United States in service. Shoreham 25 ' has had a n; cer of minor oroblems and one major probler. !' l f . ~ 1 ,
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13 1 To date, they've had problems with jacket water 2 pump propellors. This problem occurred twice.
- Two fuel 3
oil lines have ruptured due to manufacturing defects. 4 Those two ruptures resulted in Part 21 reports being is-5 i sued for San Onofre and Grand Gulf. 8 In August they had the failure of the crank- 8 7 shaft in the Number 102 diesel generator. Subsequent ; i 3 inspections of Number 101 and 103 engines revealed cracks j g in the crankshaf ts of those engines, and in approximately l to the same location as the failure of the 102 engine. i 11 UP on disassembly of the engine to repair the ' 12 crankshaft problems, connecting rod faikures were dis b e ar,'r 4 k , 13 covered, not' just on the engine with the failed crank-14 shaft but also on another engine. Subsequent inspection i is revealed problems with piston, skirts, with cracks in the 16 pisten skirts. Those piston skirts have been. replaced at 17 l Shoreham. I 18 l And, in addition, over the life of the plant 19 they have experienced several problems with different 20 types of fasteners used to attach critical components :o-21 l
, gether in the engine.
22 l The staff has received a considerable amount 23
, of information regarding marine experience from three 24 .
.different operators of marine engines. 4 Marine encines I k t.
ek 25 e t. 1
, are talking abcut, esr. the V-16 and V-12 engines . The'/ arepf i
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very similar, if not identical, to engines that are being 2 installed ir nuclear power plants in the United States. 3 The operating experience for these engines is 4 varied at this time, with engine operating hours varying 8 from 3000 to 30,000 hours. To date, all three operators 8 have reported cylinder head cracking to various different 7 extents.
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Two operators have reported piston cracking. one operator reported the complete failure of two pistons. [ 10 Problems have also been noted with excessive 11 hearing wear, turbocharger instability, and turbochargar 12 vibration. Cracks have been noted in push rody, h . ki M Cracks have been noted in connecting ' rods. 14 In addition, cylinder blocks have been replaced is by one of the operators. 16 This is a summary of the marine experience to 17 date. Is MR. DENTON: We have given you a very quick is summary, but there is extensive information available in 20 what we will hand out later in the presentation. I 21 And just because we have gone throuch it quicki'J, 22 I don't uant you to think that this is all there is. There . 23 is really quite a bit of poor operating history uith this 24 piece of equipment in the time that we have been able to i 25 ; assemble it, f i i 1.
F~~ __.._ 15 l 1 I think some of the reasons for this poor 2 performance will be obvious when you hear from our next 3 speaker, John Collins, who I mentioned heads up the ! 4 vendor inspection program. John. 3 MR. COLLINS: Thank you, Harold. Now, we are 4- passing out the view-graphs which cover a summary of the , 7 major findings that we've had of the inspection. 8 Since 1979, we have made nine inspections of .
'9 Delaval. Seven of those inspection reports are identified to in handout material. They are available in the PDR. If I
11 you would like copies and you cannot get copies, contact 12 myself in Arlington or Ian Barnes of our Vendor Br'anch, 13 we will be very happy to see that copies of these reports , 14 are sent to you. .
,3 The remaining two reports have been forwarded gg to the Company for proprietary review. That reviev ,
g7 period should be up tomorrow. If there are not any pro-18 j prietary problens, they will be placed in the PDR and they i is will be svailable, too. So, if you want to contact e,
- 2) my number in Arlington is Area Code 817-860-8205. Or, 21 Mr. Barnes, same area code, 860-8176.
22 . We have -- as' I hope everybody has the slides 23 now, our finding of deficiencies covered ;ust about ever*/ 24
; s ub j e ct. They included areas on .anufacturing process l
28 control, control of special processes, procure.ent contr:1, I i t
16 i 1 material identity and control, design and document control, 2 equipment calibration, lack if. internal audits or improper 3 or not sufficient disposition of audit findings, and then 4 deficiencies in QA records. .
-4 At this time, I am going to ask Ian Barnes, a
who is the Chief of the Reactor Section for the Vendor ! 7 ' Program to go through some of the highlights of the 8 inspection findings with you. We are not going to read { 8 them to you. You have them, but I think it's important 10 we at least identify some of them. i i
!. 11 The other handout material has a more complete .
u summary of all of the findings that were made or documented 13 in the nine reports. So, Ian, why don't you walk us g4 through some of the significant fin, dings? 18 MR. BARNES: Good af tt; acon. The first slide is that is on now shows a categorization of the vendor 17 program branch inspection findings by subject area. It is represents a total of sixty-two non-conformances and le violations that were issued as a result of the nine in-30 spections. 21 As John has just indicated, a description of 22 . all of the findings in that particular slide are in-23 { cluded in a handout that is being passed around. From 24 ; this inspection history summary, we have extracted . r 28 examples of inspection findings that raise concerns nth l t
c 1 I regard to the _ adequacy of implementation and the effective-2 ness of the Transamerica Delaval program. 3 The next slide, placie. The first subject I l 4 cm going to address is manufacturing process control. 5 We have put apccific examples of inspection findings in j s - a subject area, but ! bringing the question of implementa-7 tion ef fect toness, manuf acturing process controls, and a the perfor ance of quality function of Transamerica j s Dsiaval. i I to ?.s cou will note from this slide, ins tances 11 wers noted w.nce route sheets were not available to ' ut the Vendor F ranch review. For example, the first item on 13 the slide, jacket water pump. Reworked operations for 14 l ninety-two pistons that were supplied to Shoreham and Grand i 18 Gul f , that's the fifth iten.
- l Replacements of cylinder I
is head assemblies for Shoreham, thAt's the final item on 17
, the slide.
13 ! ?. cute sheets from Transamerica Delaval provide is the primary basis for verifying that the inspection Opera-4 l 20 ! tions haen .ecn performed. The absense of those route f 21 f sheets di.. o allow us to verify chat recuired inspections 22 j of manufseturing operations had, in fact, been accomplished. 23 i
.;xamples of" findings which address the per-I
' 24 . formance si :no uality control function is shown in the 25 second, tnard and fourth items, i.e. there was no ev fence r I o t t
13 1 l of acceptance of certain operations on components for 2 jacket water pumps pertaining to modification efforts. 3 As Ralph indicated earlier, there had been i 4 two successive problems involvin,g jacket water pump pro-
- . 5 'blems at Shoreham. And, so evidence of sign-off to
{ e installation of rocker arm hold down bolts were found , 7 subsequent at Shoreham, were found subsequent to be mis-8 sing. [; e b ,~ e In regard to San Onofre, piston reworked, with 10 tne date of sign-off for manufacturer operations occurring l 11 actually two to three weeks after the pistons had been 12 returned to San onofre. u If you look, in. regard to the seventh item on . 14 ~ . I r this list, is the apparent use as indicated by the route I 15 I
- - s sheets of -unqualified personnel performing non-descriptive 16 examinations on SNPs replacement cylinder head.
117 The eighth item, which is an absence of any 18 documented provisions for' control of installation of 19 fuel oil line clamps in regard to Shearon Harris. We 20 l believe that's generic to all of the engines, in that one 21 of the fuel oil line failures at Grand Gulf has been i 22 ! attributed in part to the absence of required line clamp. 23
. We believe this finding is quite significant.
24 . It has been r.entioned earlier about cracking 1 2 problems in piston skirts. Review of engineering fra'+1nes I i I
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19 I for the various designs of piston skirts- show, in fact, 2' that there was an engineering requirement to perform 3 stress relief heat treatment after normalizing of the 4- castings. The corrective action.that, in part, is being 5 carried out for piston skirts is to perform stress relief. s
.There was an initial requirement always in effect to do i 7 that very thing, a The next slide. This slide shows a few examples of inspection findings in regard to procurement go document control deficiencies, use of vendors , the materialsi 11 that without performing any service or audits of those I
u , vendors to establish adequacy of their own progrens, and ' 13 inadequate receiving inspection. ' 14 In the more comprehensive handout that is being , u distributed, you will find additional examples of inade-16 quate receiving inspection and using other vendors. without 17 performing required service or audits. . is Next slide. In the area of material identity is and control, an inspection of this subject showed eleven 20 discrepancies were observed in a smaple of forty-five, l-21 i I believe, in material identity between that recorded at 1
- 22 ; the time of the misuse of the material' to a given
; cb and l 3l the identity of the material that was recorded on the 24 . finished ene ne.
i i 25 !: Mext slide. We have included the next slide l
- , , - - , - . - - - - - - .,,,,.,-+a--,..-,., - . - - . . - ,_,--,,-,..__c- .
20 I l l 1 to show examples of the failure of the quality issuance 2 ! o function to comply with both QA program requirements for 3 t corrective action and non-conformance conditions to be 4
. identified and the specific instance of failure to comply 5
with corrective action commitments made to the MP.C in 6 regard to the performance of their ASME weld shop.. 7 In the same context, their ASME weld shop, recurring ex-I a amples were noted during successive inspections for g failure to enforce program commitments with respect to l 1 to control of welding electrodes in regard to that console j
. 11 moisture. !
12 Next slide. The next slide is an additional un example of the failure of the QA function to comply with
- 14 program requirements for audits of their manufacturing 15 activities.
16 The final slide, John. Ne have included this 17 to illustrate that we have certain concerns in regard to 18 the adequacy of the Delaval evaluation and reporting 19 practices in regard to 10 CFR Part 21. 20 MR. COLLINS: As we indicated at the becinning, ' 21 we have summarized in these slides the findings. But, 22 as I also indicated, I think there is a lot mo're that's 23 . of interest. If you carefully review the findings that 24 i were handed to you that were documented in the ".andeut to l u , you, one thino it says to me, in my opinion, is that I I i
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A 21 1-not only has there been problens at the manufacturing 2-shop but also, in my opinion, calls into question the 3 adequacy of the vendor programs or surveillance proghams 4 . that are being conducted by the utilities. Had some of 5 these been identified up front by utilities on-site 6 inspection pregrams, or receiving inspe.ction programs, or ; i 7 procurement programs, I think they could have been identi- ' s fled even sooner than now. . So, it really calls into question your own i 10 programs. Darrell. 11 MR. EISENHUT: Well, let's see, we went through l 12 the two aspects -in such a short, summary fashion, the I 13 operating experience and the 1nspection findings, that one ! 14 might draw connections that they infer, or might leave it 15 to the operating experience, these were meant to be short 16 summaries. We certainly are going to be, on the staff, 17 undertaking a more detailed look at all these aspects , is in both the experience, the inspection results. gg As mentioned earlier, Carl Berlinger is heading m a major review e. fort. But I guess you have to sit cack i i k 21 and say: Where does this leave us right now? 22 i And right now, our preliminary conclusion -- n ,i and that conclusion is based on these limited icoks -- is 24 that certainly our level of confidence in the overall 25 reliability of TDI diesels in general is significantl*/ I ' t o 1 . i . I e , l =
32 8 I e l i 1 reduced. We ' ve got to say that from the front end. l 2 And, secondly, as Harold Denton mentioned in l
, i 3
the beginning, is that befer.e we undertake the licensing , 4 of any plants with TDI diesels at this time, these issues 5 clearly are :otng to have to be addressed. These issues j e are clearly *.he quality aspect from both the design, the 3
. 7- construction, the operating. experience is going to have ,
a to be f actored in, and the overall ability of these diesels e to reliabl, perform their function is going to have to i 10 be demons trated. 1 i 11 ,That's basically where we are today. As we , 12 ' said early, tnd Jim McGaughy pointed out, there is a t 13 major . industry undertaking, a major program has been laid : out, that 14 we hope is going to address all of these issues. ; 13 And, obvious 1,y they are going to have to address them to to the staffts satisfaction. 17 With that as a short summary, I guess I would I is like to open it up to the staff presentation for any l lo questions be fore ve go to the second part this af ternoon go on either tece, the operating experience piece, or en 21 ' , the inspection results found today. Any questions? tt (30 reply.i .an' t get of f that easy. I 23 i i
.;e ' 1, if there are no questions, why don't 24 l I suggest .t would probably be easier, Jim, on *four 25 presentation if .<a took a short break now rather than I
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l i 1 CERTIFICATE OF PROCEEDING : I l 2 This is to certify that the attached proceeding before 3 the NRC Staff l 4 In the matter of: Meeting on TDI Diesel Generators ; Date of Proceeding: January 26, 1984 l 8 Place of Proceeding: Phillips Building, , Be thesda , Maryland a was held as herein appears, and that this is the original j 1
, transcript for the file of the Commission.
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11 - 12 MYRTLE H. TRAYLOR Of ficial Reporter - h* ped 13 P 14 18 ! Official Reporter - Signed-16 17 18 1 19 I I N 4 i 21 l 22 l . I - n l 24 2$ t
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