ML20098B581
| ML20098B581 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/29/1983 |
| From: | Hosler J ELECTRIC POWER RESEARCH INSTITUTE |
| To: | |
| Shared Package | |
| ML20093C471 | List: |
| References | |
| NUDOCS 8409260163 | |
| Download: ML20098B581 (33) | |
Text
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; PFSLIMINARY ASSESS B T OF THE THEWAL DNIRCM1ENT !N A
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i MK 111 hEih5.t-BASED ON l 1/20rri SCALE TEST RESULTS BY JatHoSLER i_ NUCLEAR SAFEW ANALYSIS CENTER l* NUCLEAR F:wER Div!SicN i ELECTRIC PcwER RESEARCH INSTITUTE 6 PRESENTATIcN TO U.S. NUCLEAR REGULATCRY CCWISSION j BETHESDA,PARYLNO 1 J l j . 9 Ju:E 29, 1983 i t l 8409260163 840910 PDR ADOCK 05000450 i O PDR l
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- CCWENTS BASE CASE DEFINITION #
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RELEASE RATE HISTORY hRELEASEl.0 : CATIONS
. t APPRCACH FOR DE:lNING THERFAL EtNIRotesta PARAMETERS t'
GAS TEM.:ERATURE
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GAS VELCCITY PnD VAPCR CCNCENTRATICN - L EADIANT HEAT Flux
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SLWARY OF CCt SERVATISP.S l THEPPAL EtulRotcErnS CEFINED l 3ASE CASE 5 l t 3ASE CASE EXTRAPCtATED TO 75% l'hR E d EASE CASE w!m HIGHER F PaEASE pan - 2 t 1 I t, r --m,-- -,, - - -,
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! BASECASEDEFINITION 1
i
- hRE'LEASERATEHISTORY ,
1 j _ RATE .
- CONTINUOUS H FLOW AT 0,8 lsM/SEC 2
BASE ON f%X FREIflCTED SUSTAINED ( 2-3 MIN) H 2 RELEASE. PATE (30!L OFF FOLLCWED BY !NTERMEDIATE FLN REFLOCO-RCIC FLW) - , DURATION
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18 MINUTES i
- PAXIMty,FERIOD -
FLOWRATE IS PREDICT G TO EXcE D O t4 tsM/SEC (THRESHOLD FOR ESTAsLISw2NT OF STANDING FL/J'ES)-- I t i , t ,
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a BASE CASE DEFINITION (CGT T)
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, RELEASE LOCATICfis 8 ADS + 1 SORV SPARGER (9 TOTAL)
I 1/20THSCALE-TESTINDICATESSPARGERFLCWISLIMITIt!G(vsi.0CA VENT FLOW) . 1/20Tri SCALE TEST INDICATES LOCAL INCREASE IN RELEASE (DUE
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TO AIUACErfi SEW SPARGER) IS LIMITING (vs 8 ADS ALONE)
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l I APPROACH FOR DEFINING THEWAL EhYIR000Efi PAP #1ETE?S i
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4 GAS TUP ; GAS VELOCITY , ( HpVAPORCCNC, FADIAhT HEAT FLUX e-e u DUE TO F 0 2
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DUE TO HOT GRATING I e F 4 4 % l
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DE INITION CF THEFFAL BNIRCff9fT PARAMETERS (CGtPT)
- I GAS TEMP FOR 3ASE Q SE MAX TEMP OSSE.% E FCR ALL (FASE CASE) TESTS EXCEFT CtE. GAS 4
TEMP FOR 1 TEST WAS 136*F ABOVE THAT SELECTED. FcR HIGH FLCW CASE MAX TEFP CSSERVED FOR ALL HIGH FLOW (2.0 tsM/SEC FULL SCALE) TESTS i
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s DEFINITION OF THEFFAL ENVIR0fiW PAFJPti RS (CCN'T) i *
, GAS VELOCITY WAS ESTIPATED USING THE. MEASURED C0tNECTIVE HEAT., FLUXES AS FOLLOWS: ,
- 1. THECcNvdCTIVEHEATTRR4SFERCCEFFICIENTWASESTIPATEDASFO <
i H CBSERVED CONVECTIVE HEAT FLUX CBSERVED T NEAR FF SENSOR
- 2. l USING THE H FRCt4 (1) THE Nu # WAS CCMPLETED NO BE Fi # CBTAINED
', EASED ON THE CCRRELATION OF Nu # To RE FOR JLCW OVER A SFHERE,
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- 3. VEL WAS CCP.F'JTED FRCf4 THE Ps # OsTAINED IN (2).
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{ DEFINITION OF TrSPAL EhVIPDFB4T PARTItPS (C8N'T) i . GAS H O VAPOR CONCENTRATION 2 AssuMPTICns: . , INITIAL y VAPOR CONC. 16% (hs e CN INITIAL gas TE.vp) I
- 2H 2 + 02 + 4IS
- F20l l
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3HO+4th 2 Fitw. P20 VOL : = 3/7 43% . e-1 i l 8 3 e j 1 b l L .. _ .
.. . . . __ . . . . _ . . _ . _ . \
l . DEFINITION OF THERMAL ENVIRONMENT PARAMETERS (CONT'D)
. RADIANT HF 5
. 2 S0 RCES :
. 1 H2O VAPOR RADIATION 2 RADIATICt! FROM HOT GRATING
. DATA EVALUATION -
HOTTEL CHARTS USED TO ESTIMATE H2O VAPOR RADIATION FOR
- 1/20TH SCALE GEOMETRY'AND MEASURED TEMPS.
BLACK EODY RADIATION COMPUTED FOR GRATING RADIATION USING ESTIMATED VIEW FACTORS AND MEASURED TEMPS AT 1/20TH SCALE. PREDICTED TOTAL RADIATION HF' AGREED WELL WITH MEASURED RADIATION HF (TOTAL - CONVECTIVE).
. F.S. RADIATION HF DEFINITION HOTTEL CHARTS USED FOR H 2 O VAPOR RADIATION FOR F.S.
GEOMETRY AND SAME TEMFS, RADIATION FROM GRATING COM?UTED FOR F.S. VIEW FACTORS AND MEASURED TEMPS. i . i ) I i
~ ~ ~ * - *
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- : CONSERVATISMS IN APPROACH FOR DEFINING F.S. THERMAL ENVIRONMEtli
- 1. I 1/20TH SC' ALE TEMPS HIGHER THAN PROTOTYPE.- ,
. LAMINAR EFFECTS (TALLER FLAMES).
WORST LOCATICN IN CONTAINMENT CHOSEN. . NO SPRAYS. _ NO PIPING / EQUIPMENT AND HEAT SINKS.
- 2. CONTINUOUS BURNING ASSUMED. .
~
ACTUAL H2 RELEASE IS LIKELY TO BE MUCH MORE INTERMINTENT. ( i I . . ( i - .
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THERMAL ENVIRONMENTS DEFINED
- 1. BASE CASE i
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GAS TEMP FROM FIGliRE I 18 MIN UURATION GAS VELOCITY - 36 FT/SEC RADIANT HEAT FLUX (FROM BELOW) - 6500 BTU HR-FT2
- 2. BASE CASE EXTRAPOLATED TO 75% MWR GAS TEMP SPATIAL / TEMPORAL DISTRIBUT. ION FROM FIGURE 2 OTHERPARAMETERSSAMEASBASE._ css.E
- 3. BASE CASE WITH H FLOWRATE = 2,0 tsM/SEC FULL SCALE 2
MAX GAS TEMP - 1200*F (BELOW HCU FLOOR) DURATION 7,2 MIN (SAME TOTAL H2 AS BASE CASE) 21.7 MIN (75% MWR) GAS VELOCITY - 50 FT/SEC
- RADIANT HF (FROM BELOW) - 16,500 33 HR-FT .
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ANALYTICAL MODEL
. HEATING-3 . MULTI-DIMENSIONAL TRANSIENT HEAT CONDUCTION FORCED &N'ATURALCONVECTION, RADIATION
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THERMAL BOUNDARY CONDITION DATA - 1/20 - SCALE TESTS GAS TEMPERATURE (TEMPORAL & SPATIAL) 2
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GAS VELOCITY (IEMPORAL) RADIANTHEATFLUX(TEMPORAL &${ATIAL)
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_ NO SPRAY COOLING H; IGNITER ASSEMELY WETWELL LOCATION - 2.5 FT. BELOW HCU LEVEL MATERIAL COMPOSITION 5 STAINLESS STEEL - HOUSING, SPRAY SHIELD, JUNCTION 30X METHYLVINYL $1LOXANE - GASKETS i ? PHENOLIC - TERMINAL 3 LOCK.
- a COPPER 8 IRON - TRANSFORMER ,
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~U IGNITER 00X TRANSFORMER IEMPERATURE - 2.5 FT. DELOW llCU - 2 MARCll i y_
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g IGNITER DOX TRANSFORMER TEMPERATURE - 2 5 FT. DELOW HCll .8 MARC!! o 731 ft W RIN O o ., t. f
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l CONCLUSIONS ti
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STANDING FLAMES ON POOL SURFACE. EXPECTED FOR H2 RELEASE-i -. . .
~I RATES AB0VE 0.4 1.sM/sEc
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4 . RESULTING THERMAL LOADING TO EQUIPMENT IS: UNACCEPTABLE FOR 75% MWR q LIKELY ACCEPTABLE FOR REALISTIC SOURCE TERM , t e
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s . 4 0 Se IGNITER EFFECTIVENESS . STUDIES i AECL - WNRE
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TO INVESTIGATE THE EFFECTIVENESS OF llYDROGEN - AIR
- STEAM IGNITION SYSTEMS NEAR Tile RICil LIMITS (UFl.) FOR BOTil OUIESCENT & TURBULENT CONDITIONS. -
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#ENimED IGNITION CONDITON VOLTAGE O e O STATIC ~ 12 VOLTS 5 5 O STATIC 14 VOLTS
< Y Y V TURBULENT 14 VOLTS -
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luSING A GM AC MODEL NO.7 T+iERMAL GLOW PLUG LOCATED AT THE E" LITRE @F A 47-UTRE QUASI - SPtiERICAL VE.SSEL. t ! i. i*
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t i- . MEASUREMENTS
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. e INITIAL COND'ITIONS: - TEMPERATURE
- PRESSURE PARTIAL PRESS.
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;- TRANSIENT CONDITIONS: - TEMPERATURE => COMBUSTION
- PRESSURE -:> PEAK
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FINAL CONDITIONS: -PRESSU5E
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. 1 CONCLUSIONS .
FOR HYDROGEN - RICH MIXTURES: 1
- 1. IGNITION LIMITS WITH GLOW PLUG INGITOP AGREE WITH FLAMMABILITY LIMITS. -
- 2. FAN-!NDUCED TURBULENCE DOES NOT AFFECT THESE LIMITS.
- 3. " MARGINAL IGNITION" IS NOT OBSERVED.
}4 . IGNITION TEMPERATURE IS NOT A STRONG FUNCTION OF STEAM
~
CONCENTRATION. ,
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. . _ . . - - - - . - .,-, ...~ .-- -
4 b , H2RICH TESTING EVALUATION * (
. . DATA PRESENTED CONFIRMS IGNITION POINTS ASSUMED IN "CLASIX" ANALYSIS OF DRYWELL COMSUSTION E
, REDUCTION OF CONDENSATION TESTS DATA IN-PROGRESS - .
8 EVALUATION TO FOLLOW a w e , D 9-
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, i i
. . . . . . . . .. . . . . - - - . - - ... - -- - - - -- - l l
s . l 1 . l 1/4TH SCALE TEST PROGRAM STATUS .
! . SUPPORTING SCALING ANALYSIS COMPLETE
. PRELIMINARY DESIGN HAS UNDERGONE HCOG DESIGN REVIEW ,
. HCOG HAS DETERMINED THAT PROCEEDING WITH THE 1/4TH SCALE i i
TESTS IS NOT WARRANTED,
'I
. - ~
i i - I
.a . . INVERTED FLAME TEST PROGRAM STATUS l 1
. HCOG HAS COMPLETED AN EVALUATION OF INVERTED FLAME TESTING i l
. CONCLUDED THAT TEST PROPOSED TEST IS NOT WARRANTED ,
INVERTED DIFFUSION FLAME,S ARE WELL UNDERSTOOD PHENOMENA REDUCTION IN SOURCE TERM TO REALISTIC VALUES WILL MITIGATE HEAT ADDITION T0.THE DRYWELL > e 6 e. h e P e 6 8 s 8 i
]
I. . . . RAls/EPGs RAls.SUEMITTED TO NRC BY'HCOG ON MAY 11, 1983 IN HGN-011 : 4
. DRAFT EPG FORWAR'vED TO BWR OWNERS GROUP EMERGENCY PROCEDilRE SU3 COMMITTEE FOR REVIEW 1
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HYDROGEN CONTROL EMERGENCY PROCEDURE GUIDELINE e DRAFT EPG FORWARDED TO BWR OWNERS GROUP EMERGENCY PROCEDURES COMMITTEE f o ENTRY CONDITIONS RPV WATER LEVEL BEI.OW TOP OF ACTIVE FUEL OR CAN'T BE DETERMINED CO!CAINMENT OR DRYWELL EYDROGEN CONCENTRATION APPROACHING 3% L o OPERATOR ACTIONS . _ _ START HIS MONITOR DRYWELL AND CONTAINMENT HYEROGEN CONCENTRATION
- START EYDROGEN RECOMBINERS
- SEUTOCWN EYDROGEN RECOMBINERS ON EIGH EYDROGEN CONCINI?AT!CN A
- MONITOR CONTAINMENT TEMPERATURE
- INITIATE CONTAINMENT SPRAY ON HIGH CONTAINMENT TIMPERATURE I_?, ADEQUATE CORE COOLING IS ASSURED
- INITIATE CONTAIUMENT SPRAY ON HIGH-EIGH CO!CAINMENT TEMPERATURE RIGARDLESS 17 A0ECCATE
,' CORE COOLING IS ASSURED i
.4
m he At a:r.cen8'2 EWR - HCOG MEETING June 29,19E3 Name A f fil ia -icn Carl Stahle NRR C. Tinkler NRR' , J. Shapaker .. NRR . A. Notafrancesco NRR D. Houston NRR A. Schwencer NRR Garry R. Thomas E:RI/N5AC . , T. M. Su NER R. Tripathi ACES < R. W. Evans Evan:ot Se-vices S. H. Hobbs MF&L Marvin Morris - GSU E. M. Suzzelli CEI- , J. J. Stefano NRR - ! W. E. Coleman CEI : Erwin J. Zoch GSU 1 Erich Kant iLL F:wer Cc. R. W. Houston -- NRC - Richard C. Corlet-
- EPRI Consultant <
John Hosier EPRi/NSAC allen L. Camp Sandia Labs , Joseph E. Shepherd t Sandia Labs John C. Cummings Sandia Labs _ John C. Lane N'RR - John Carey EPRi/NSAC ! A. David Rossin EPRI/NSAC M. Lloyd Middle South Services, Inc. v.evin W. Molt claw General Electric Gerry Presby Cleveland Electric G . M. Ful s Westinghouse - OPS J. R. Maley MP&L E. F. G::dein Stone i Webs ter Engineeri .; C:r:. 6.en Ferry Westinghouse - OPA J:hn Long NRC
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- Ja:k f.udrick NRC l J:rn 7. Larkins *
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pmargo y ft ),i UNITED STATES NUCLEAR REGULATORY COMMISSION s, y WASHINGTON, D. C. 20555 N'***** / . January 18, 1984 Docket Nos. 50-289,483,382, 50-275/323, 247/286 e MEMORANDU:1 FOR: Chaiman Palladino Comissioner Gilinsky i Comissioner Roberts . Comissioner Asselstine Comissioner Bernthal FROM: Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
NRC USE OF THE TERMS, "IMPORTANT TO SAFETY" AND
" SAFETY RELATED" (BOARD NOTIFICATION 84-011)
In a~ccordance with oresent NRC procedures regarding Board Notifications, the enclosed is orovided for your infomation. This information fs aonlicable to all nuclear power olants. By cooy of this memorandum, we are notifying aporopriate boards and parties. Enclosure 1 clarifies the staff's position regarding the subject matter and is relevant to safety issues before the Boards, especially in the area of quality assurance. Enclosure 2 is a utility / industry request for dialogue on the subject matter. Enclosure 3 orovides the staff's response to Enclosure 2.
\
,, x
/
l'd.' Ei e Qb,jSi ctor Da r Division of Licensing
; Office.of Nuclear Reactor Regulation Enclosure 1: Memo DGEisenhut i to All Licensees, etc. GL-84-01) .
Enclosure 2: Ltr, BLHarshe to ' H.J.Dircks, undated Enclosure 3: Ltr, HRDenton to '. . - BLHarshe, dtd 1/5/84 = n ym cc: See next page i
r- % , i 2-cc: OPE OGC EDO - SECY (2) The Atomic Safety and Licensing Boards for: Byron (Miller, Callihan, Cole) . Callaway (Gleason, Bright, Kline) Catawba 1 & 2 (Bloch, Jordan, McCollom) Diablo Canyon (Holf, Bright, Kline)
- Limerick 1 & 2 (Brenner, Cole, Morris)
Midland 1 & 2 (Sechhoefer, Cowan, Harbour) Perry I & 2 (Bloch, Bright, Kline) Seabrook 1 & 2 (Hoyt, Harbour, Luebke) Shoreham (Brenner, Carpenter, Morris) Waterford 3 (Wolfe, Forenan, Jordan) Wolf Creek (Wolfe, Anderson, Paxton) Zimmer (Frye, Hooper, Livingston) The Atomic Safety and Licensing Aopeal Boards for: Callaway 1 (Rosenthal, Edles, Gotchy) Diablo Canyon 1 & 2 (Moore, Johnson, Buck) - Zimmer (Rosenthal . Eiloerin, Wilber) TMI-1 (Edles, Buck, Gotchy, Kohl) Shoreham (Rosenthal Edles, Wilber)
'laterford 3 (Kohl, Johnson, Wilber)
All parties for the above proceedings 1 e 1 l
y [ Enclosure 1 ef* "%.,,% UNITED STATES [3-[} NUCLEAR REGULATORY COMMISSIO.\
.vAsmNorou. o c. mss l
January 5, 1984
. TO ALL HOLDERS OF OPERATING LICENSES, APPLICANTS FOR OPERATING LICENSES AND HOLDERS OF CONSTRUCTION PERMITS FOR POWER REACTORS , Gentlemen:
Subject:
NRC Use of the Terms, "Important to Safety" and " Safety Related" (Generic Letter 84-01) As you may know, there has been concern expressed recently by the Utility Classification Group over NRC use of the terms "important to safety" and
" safety-related." The concern appears to be principally derived from recent licensing cases in which the meaning of the terms in regard to NRC quality assurance recuirements has been at issue, and from a memorandum from the Director, Office of Nuclear Reactor Regulatien, to NRR personnel dated November 20, 1981.
Enclosed for your information are two letters to the NRC from this Group, and the NRC resoonse dated December 19, 1983. In particular, you should note that the NRC reply nakes it very clear that NRC regulatory jurisdiction involving a safety matter is not controlled by the use of terns such as
" safety-related" and "important to safety," and our conclusion that pur-suant to our regulations, nuclear power plant permittees or licensees are responsible for developing and implementing quality assurance prograns for plant design and construction or for plant operation which meet the more general requirements of General Design Criterion 1 for plant equipment "important to safety," and the more prescriptive requirements of Appendix 2 to 10 CFR Part 50 for " safety-related" plant equipment.
While previous staff licensing reviews were not specifically directed towards determining whether, in fact, permittees or licensees have developed ouality assurance programs which adequately address all structures, systems and com- - ponents important to safety, this was not because of any concern over the lack of regulatory requirements for this class of equipment. Rather, our practice was based upon the staff view that normal industry practice is oenerallf acceptable for most equipment not covered by Apoendix 8 within
, this class. Nevertheless, in sp :ific situations in the past where we have found that ouality assurance requirements beyond normal industry practice were needed for equipment "important to safety," we have not hesitated in imposing additional reouirements comensurate with the importance to safety of the equipment involved. We intend to :ontinue that practice.
G 11& , n cM%0 - u mu - L
5 The NRC staff is interested in your comments and views on whether further guidance is needed related to this issue. If you are interested in partici-pating in a meeting with NRC to discus!, this subject, please contact Mr. James M. Taylor, Deputy Director, Office of Inspection and Enforcement. Sincerely,
- \ s ( f O
r
/ i l 1
rrell G.' Etidnhut, frector Division o' L'1 censing l
Enclosure:
1
- 1. Two Letters from Utility Safety .
; Classification Group '
- 2. NRC Response dated December 19, 1983 i
~
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f 1 i [ l Hexrox & WILLIAxs - l 7o7 EAs? MaaN SfetCT A. o. Som '535 k l 0 e a t swiLoimo Rzcuxown, VInotarA 20s a . e . e . v. ~ . . v. . . .. c = w s. .. r e.o.comice e o. een r easo ct6cio=. mome= camovma areca ***" ' ** Cee eae.este faste=omt 804-788 6200 aca ass eeso ees+ coo + e*=a '=wca 3 .o. 3.e. ~o-
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- August 26, 1983 1
e e Mr. William J. Dircks U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, Maryland 20814
Dear Mr. Dircks:
The Utility Safety Classification Group, a group repre-l l senting 30 electric utility owners of nuclear power plant s,1.' seeks to bring to your attention an issue of major importance l I and increasing prominence, namely that of certain defin*.tions l l used in systems classification. The regulatory terms " safety 1 related" and "important to safety" and the non-regulatory term
" safety grade" have been consistently used synonymously by the e
industry and the NRC over decades of plant design, construc-l tion, licensing and operation. The Utility Group believes that various recent actions
, taken within the N#C Staff signal a sharp departure from the
,1./ Members of the Utility Group are listed in Attachment A to this letter. The Utility Group has retained the firm of *MC / as its technical consultants and the law firm of Hunton & Williams as its legal consultants.
. , . n n M' j w '] W W W ~ f e _ _ _ _ - - - _ _ - - _ _ - - - - _ _ - - - - - - _ _ - - . - _ _ -. __
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I Et:Wrox & WILLIA >ts r August 26, 1983 Page 2 f long-standing meaning of the term "important to safety" to cover a much broader and undefined set of plant structures, . systems and components than is covered by the term " safety re-lated." Redefining these terms without proper review would l t likely have far-reaching, pervasive consequences for licensing and general regulation of nuclear plants. In particular, given the extensive use of the term "important to safety" in the Com-l mission's regulations and Staff regulatory guides, NUREG docu- t ments and other licensing documents, as well as licensee sub-mittals, the result of this sharp departure from the long-standing meaning of 'this term would be a largely unexamined and j perhaps unintended expansion of the scope of the above docu-j ments. The Utility Group believes it is vital that the Commis-i sion be aware of this development so that steps can be taken to ensure that if any changes to regulatory requirements and guid- , i j ance are made, they are made only in a manner consistent with l legal requirements and after a thorough consideration of their ! l consequences and ramifications. This process should include 4
; consideration oy the Committee to Review Generic Requirements. .-
! Contrary to all this, the Utility Group understands that a ge-l neric letter will soon be sent by the Director of the offica of { l
r_ _ _ l t Et:xTox & WILLIAMS . August 26, 1983 Page 3
- Nuclear Reactor Regula:1cn, requesting all licensees and applicants to describe their current treatment of structures,
. systems and components "important to safety. " Such a letter incorrectly assumes that "important to safety" is different from " safety related."
Since the introduction of these terms in the NRC's reg-ula:1ons, nuclear plants have been designed and built by mem . bars of the nuclear industry, including the members of this Utility Group and their contractors, using the terms " safety related" and "important to safety" interchangeably.2/ The terms "sa.fety related" and "important to safety" are us.d in the Commission's regulations.3/ Plants designed using this 2/ A functional definition of these structures, systems and components "important to safety" or " safety related" is found in Part 100, Appendix A. They are those structures, systems
. and components relied upon, in the event of a safe shutdown earthquake, to fulfill the three basic " safety functions" of assuring (1) the integrity of the reactor coolant pressure
, boundary, (2) the capability to shut down the reactor and main-tain safe shutdown and (3) the capability to prevent or miti-
.. gate the consequences of accidents which could result in offsite exposure comparable to Part 100 exposure guidelines.
10 CFR Part 100, Appendix A, if I, III(c). 3/ To a lesser extent, the non-regulatory term " safety grade" 3 is part of this issue. Safety grade is commonly regarded as i being synonymcus with " safety related" and "important to safe-ty." , l r
Hux rox &. WILLI Axs August 26, 1983 Page 4
- lassification scheme were licensed by the NRC and, indeed, the NRC has recogniked the equivalency of safety related and impor- .
tant to safety in many documents.4/ The issue. addressed by this letter is similar to, but distinct from, that faced in the TMI-l restart proceeding. There, the Union of Concerned Scientists, an intervenor, argued that certain components of TMI-1, previously classified as non-safety related, should be upgraded in their design criteria to " safety grade" status. The arguments in that case, highly . fact-specific, were limited to the actual components .st issue, were couched in terms of the non-regulatory term " safety grada," and applied only to design requirements (as contrasted with'.e.g., QA requirements). Thus the decisions of the L1-censing Beard ( L3P-81-59, 14 NRC 1211 (1981)) and the Appeal Board (ALAB-729, May 26, 1983) in TMI-1, are not susceptible, j upon close reading, of broader application to the " safety re-Lated"/"important to safety" issue addressed by this letter.5/ i 4/ See Attachment B to this letter for examples of instances - in which the NRC Staff has used these terms interchangeably. 5/ The Appeal Board in the TMI decision,'while upholding the Staff's distinction between the terms " safety grade" and "im- [ . portant to safety," found the Staff's explanations " confusing l and its attempt to define ( those terms ] somewhat belated." ALAB-729 at 137 (slip op.) n.288.
Ht:xTox & WILLIAxs August 26, 1983 Page 5 - Ur.fo rtunately, these decisions are being improperly cited with-
. in the Commission, in contexts different from TMI-1, to imply an enforceable regulatory distinction between the terms " safety related" and "important to safety." Also, because the focus of the hearing in TMI-l was so narrow, the record did. net consider the broader implications of an expanded definition of "impor-tant to safety," nor did the record include facts establishing the long-standing industry and NRC practice of equating "impor-tant to safety" and '.' safety related. "
The present issue was framed by a November 20, 1981 memorandum from NRR Director Harold Denton to all NRR person-nel, following the close of the TMI-1 record. This memorandum, which has never been circulated for public comment, argues that the category "important to safety" is broader than " safety re- , lated" (or " safety grade"). Significantly, the memorandum also l l , -disclaims any intent to alter existing regulatory requirements. Despite the disclaimer, revision of the definition of "impor-tant to safety" to make it a broader category than " safety re-lated" could have far-reaching, pervasive consequences for the licensing and~ general regulation of these plants. The Denton definition of "important to safety" is plainly inconsistent l l
)
Hcrrox & Wir,LIAxs August 5, 1983 . Page 6 1 with at least a decade of industry and regulatory usage, in relianc on which dozens of plants have been designed, ordered, and bui t. . In addition, a number of recent events have taken place , ! on the ajustified assumption that the Denton distinction be-tween " afety related" and "important to safety" is correct. They in :1ude, for example, the Staff's advocacy of the new, ex-j panded .eaning of the terms " safety related" and "important to safety" in various licensing proceedings; preposal and promul-gation f rules purporting to distinguish between " safety re-lated" nd "important to safety" equipment.(e.g., ATWS,.Envi-ronment:1 Qualification); commissioning of various contractor studies and issuance of various Staff documents premised on a distinc-ion between the terms (e.g., EG&G Draft Report on grad-ed QA). These are described in more detail in Attachment C to i this le ter. At the same time, numerous Staff documents, some more re ent than the Denton me.norandum, read fairly, presume the cor inued vitality of the view that the terms " safety re- ., lated" nd "important to safety" are synonymous. Examples of these t ages are also described in Attachment B. Against this backgrc nd, the apparently impend'ing issuance of a generic NRR i .
, . - - - - -~ . . - . - -. .- ,,-...
H t:rr o x & W i t.LI.t x s August 26, 1983 Page 7 letter requesting utilities to account for treatment of items
. "important to safety" can only exacerbate existing confusion. . The impetus for the NRC Staff's efforts to axpanc the definition of "important to s'afety" seems to be a desire to ex-pand some measure of design and quality regulation beyond the traditional scope of the NRC's regulatory authority. Whether such a desire is justified is not the direct focus of our let-ter. This Utility Group celieves that a Staff redefinition of a basic regulatory term such as "important to safety" in an in.
ternal memorandum is not the appropriate means to accomplish, this goal. It is also important to note that while variations exist in the details of practice, industry as a whole has gen- , erally applied design and quality standards to non-safety re-lated structures, systems and components in a manner commensu-rate with the functions of such items in the overall operation of the plant. Moreover, we understand -hat numerous industry and professional groups, including AIF and ANS, are currently addressing the issue of quality assurance and quality standards l for the non-safety related set of structures, systems and com-l ponents. This Group and other groups plan to work closely with the NRC Staff to address the issue in a thor.oughly.and carefully considered manner.
H t:xT o y & WI LLI.or s August 26, 1983 Page 8 i In light of all this, the Utility Group urges you and the office of Nuclear Reactor Regulation to delay indefinitely the issuance of the proposed NRR generic letter and to pursue instead a course of action on this issue which includes a con-sideration of the views and experience of industry on the ques-tion and the consequences of additional regulation before for-mally articulating any new definitions. In this way NRR can learn in more detail whether such definitions will, in fact, impose new requirements rather than merely clarify existing ones. Also, unforeseen and unintended consequences in these , and other areas of the regulations can be avcided and an ade-quate cost-benefit assessment can be made if the views of af-fected parties are obtained and considered in an orderly fashion. Should the Staff decide nonetheless to issue the ge-neric letter, we request that this letter on behalf of the Utility Group and the attachments be enclosed with ths generic - letter and with any Board notifications that may be issued on the subject. The number of ongoing activities potentially affected by the definition of "important to safety" and the informal na-ture of the Denton Memoranduni make it difficult to determine
, ,. .~.n..
.+4 , e --, v - - --- -- --- - - - - - - - - - ' ' - * - - - ' - - ~ -
i Ht:xrox & WILLI Axs August 26, 1983 Page 9 the appropriate procedural avenue to be pursued. The , differences in approaches reflected in Attachments B and C to this letter may be the result of misinterpretation or misunder- ~ standing that the Staff may be able to correct, as suggested above. On the other hand, if efforts to resolve this matter on the Staff level fail, the most constructive way of advancing and clarifying thought on this important subject may be a rulemaking proceeding. We would appreciate your prompt re-sponse so the Group can take the apprepriate action, Sincerely yours,
. ; e
; }' "
t : . _ , J k . . c, Cl' ~ .' ,. . j *; f
-T. S. Ellis,' III-Donald P. Erwin ,
Anthony F. Earley, Jr. . Counsel for Utility Safety Classification Group l 1 er- .- -v , ,, e-, , - -r
l Huxro x & WI LLI.tx s - August 26, 1983 Page 10 . cc: Mr. Harold R. Denton Mr. Richard C. DeYoung Mr. Robert B. Minogue Mr. John G. Davis - Guy H. Cunningham, III, Esq. Mr. Victor Stallo, Jr. Mr. Richard H. Vollmer . Mr. Darrell G. Eisenhut 3r. Thents P. Speis Mr. Toger I. Mattson Mr. Hugh L. Thompson O e W e b n - a
ATTACIDtENT A - - MEMBERS OF THE UTILITY SAFETY CLASSIFICATION GROUP Arkansas Power & Light Co. . (representing also Mississippi Power & Light and Louisiana Power & Light) Saltimore Gas & Electric Co. . Cincinnati Gas & Electric Co. Commonwealth Edison Co. Consumers Power Co. Detroit Edison Co. Florida Power Corp. Florida Power & Light Co.
- Illinois Power Co.
Long Island Lighting Co. Niagara Mohawk Power Corp. Northeast Utilities Northern States Power
, Pacific Gas & Electric Co.
Pennsylvania Power & Light Co. Public Service Company of Indiana Public Service Company of New Hampshire (representing also the Yankee Atemic Electric Power Ccmpany) - Public Service Electric & Gas Co. Rochestar Gas & Electric Co. Southern California Edison Co. Sacramento Municipal Utility District SNUPPS (representing Union Electric Co., Kansas Gas & . Electric Co., Kansas City Power & Light Co., and Kansas Electric Power Coop., Inc.) Toledo Edison Co. i
- Wisconsin Electric Power Co. .
, - - . - - _ . . . _ . - y , - . . . , .-.
ATTACHMENT B . Examples of the Equivalent Usage of "Important to Safety" and " Safety Related" I. Introduction Since the inception of its use, the term "important to
, safety" has been consistently used synonymously with the term
" safety related." The nu'elear industry designed and built many nuclear power plants based on the equivalency of these terms, and the NRC, in turn, reviewed and licensed these plants on the same basis. This practice of equating "important to safety" and "safesty related" has a sound basis in the NRC's regulations and has been reflected in numerous NRC guidance documents. The purpose of this attachment is to describe examples of NRC regulations, regulatory guides, NUREGs and other guidance documents in which the terms "impcrtant to safety" and " safety related" have been used in a way that evidences an intent to equate those terms. This list is not intended to be
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comprehensive; rather it includes only representative examples of the synonymous usage of these two regulatory terms.
II. NRC Regulations A. Part 50, Accendix A As proposed in 1967, Part 50's Appendix A did not use the term "important to safety." See 32 Fed. Reg. 10,213 (1967). In the version adopted in 1971, however, the term appeared in a number of places. The Federal Register notice adopting Appendix A discussed the substantive changes between the proposed and final rules. Significantly, this discussion of substantive changes did not mention the addition of the term "important to safety." This strongly suggests that the drafters did not consider that the change in terminology made any difference in scope or subctance.' See 36 Fed. Reg. 3256 (1971). A comparison of the proposed and final rule reveals that "important to safety" was merely substituted for a number of similar terms referring to features that are now known as
" safety related." .
The principal instance of this exchange of equiv'alent l terms was the substitution of " structures, systems and . t components important to safety" for " engineered safety . features." " Engineered safety features," as defined in . Criterion 37 of the proposed Appendix A, are those provided to assure the safety provided by the core design, the reactor coolant pressure boundary and th'eir protective systems. At a minimum, " engineered safety features" are designed to cope with all reactor coolant pressure boundary breaks up to and
i l _3 including the circumferential rupture of any pipe in that
. boundary, assuming unobstructed disch'a: ge from both'-its ends.
~
- See 32 Fed. Reg. 10,216-17 (1967). In other words, " engineered safety feature" in the proposed Appendix A is essentially similar to the current terminology of 10 CFR Part 100, particularly 53 100.2(b) and 100.10(a) and (d), and it clearly falls within the ambit of " safety related" as that term is defined in Appendix A to Part 100.
Other examples exist of this substitution of "important to safety" for " engineered safety features." Proposed GDC 3, ) which now applies to structures, systems and components "important to safety," specifically referred in an earlier version to " critical parts ei the facility such as the . . containment and control room as "engineared safety features." See 32 Fed. Reg. 10,215. And GDC 4, which also now applies to structures, systems and components "important Oc safety,' evolved from proposed versions of GDCs 40 and 42, which dealt with " engineered safety features." See 32 Fed. Reg. 10,217
~
(1967). By the same token, the current GDC 20 requires, in part, that protection systems be designed to sense accident cenditions and to initiate the operation of systems and , components "important to safety." This portion of GDC 20 evolved from an earlier, proposed version of GCC 15, which required protection systems to sense accident situations and to initiate the operation of necessary " engineered safety I features." See 32 Fed. Reg. 10,215 (1967). Here again, there 1 i l
.. . - . . - .. - - . - . . . - - _ - . - . .. -- .\
4 is an unmistakable equation of "important to safety" with
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" engineered safety features," a term that refers to safety related features. .
The current GDC 44 requires a cooling water system to transfer heat from structures, systems and components ,
"important to safety" to an ultimate heat sink. The cooling water system requirements in GDC 44 evolved from p.oposed GDCs 37, 38 and 39, which established the design basis of
" engineered safety features" and stated the requirements for them. See 36 Fed. Reg. 10,216-17 (1967). Thus, the cooling water systen referred to in GDC 44 is, in reality, the safety related engineered safety feature necessary to support other engineered safety features previously discus:ed in the proposed Appendix A.
Yet another example is provided by existing CDC 16 which requires a reactor containment and associated systems to assure that containment design conditions "important to safety" not be exceeded during postulated accident conditions. This GDC evolved from GDC 10 of the proposed Appendix A, which required the containment structure to sustain the initial - effects of gross equipment failures, such as a large coolant boundary break, without loss of required integrity and, together with other " engineered safety features," to retain for 1 as long as necessary the capability to protect the public. See 32 Fed. Reg. 10,215 (1967). In other words, the' containment design conditions in the proposed GDC dealt with loss of
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describe what are now known as " safety related" structures, i systems and components, that the drafters beli,eved there wa.s no significant difference between "important to safety" and tha ; terms used in the proposed version of the rule, and that the i structures, systems and components referred to in Appendix A, - regardless of what they are c'alled, perform those functions now regarded as the safety related functions. Consequently, it is proper to conclude, and industry justifiably d' di conclude ~, that "important to safety" and " safety related" were equivalent terms. 1
- 3. P_ art 50, Accendix B i 3cth the NRC Staff and industry agree that Appendix 3 applies only to safety related structures, systems and components. This conclusion follows from the preposed and final versions of Appendix 3 which apply, by their terms, to activities affecting the " safety related" functions of structures, systems and components that prevent or mitigate the -
consequences of an accident.1/ 34 Fed. Reg. 6600 (1969); 35 Fed. Reg. 10,499 (1970). Thus, unless a structure, system or component has a safety related function, Appendix 3 does not apply to it. Appendix 3 alEo states that it applies to
" structures, systems and components that prevent or mitigate 1/ The prevention and mitigation of the consequences of 1
. postulated accidents, of course, are among the safety related functions of 10 CFR Part 100, Aprendix A.
_ ,-- _ _ . . _ . . _ . . _ _ _ . . . _ , - . ~ _ _ _ , ~ . _ - . - . - , . _ . - . . . _ . _ _ _ _ - . . . _ _ _ . . _ . - _
l l [ ! l l the consequences of postulated accidents that could cause undue risk to the health and safety of the public." 10 CFR Part 50, Appendix 3, Introduction. This definition of the scope of Appendix S is essentially identical to the definition of
. "important to safety" found in the Introduction to Appendix A.
other evidence of the equality of " safety related" and "important to safety" is also.found in the proposed Appendix 3 rulemaking. The notice of proposed rulemaking stated that its quality assurance criteria would supplement GDC 1 of proposed Appendix A, previously noticed in the Federal Register in 1967. 34 Fed. Reg. 6600 (1969). It appears frem this statement that
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Appendix 3 was meant to specify, in detail, what the general ' provisions of GDC 1 meant. This interpretation is supported by the fact that Appendix 3 was intended to " assist 'applicants (1)
. to comply with Section 50.34(a)(7) . . . ." Section 50.34(a)(7) states that Appendix 3
- sets forth the requirements ,
for quality assurance programs" (emphasis added), and i presumably "the requirements for quality assurance programs" include those of GDC 1. Thus, a reading of the regulatory history implies that Appendix 3 is a more detailed specification of the requirements contained in GDC 1, thereby equating "important to safety" with " safety related." C. Part 100, Aependix A The interchangeability of the terms " safety related" and "important to safety" is vividly illustrated by a review of
i. t I the regu.atory history of 10 CFR Part 100, Appendix A, which was proposed on November 25, 1971. 36 Fed. Reg. 22,601. The pr: posed rule included a number of passages that make assolutely clear (1) the category "important to safety" in 1971 mean: ' safety related" and (2) the terms are to ba used incarchangeably. For example, in defining the " Safe Shutdown . Earthquake," the proposed rule stated: (c) The " Safe Shutdown Earthquake" is that earnhquake which produces the vibratory ground motion for which structures, systems l and components important to safety are l designed to remain functional. I . These structures, systems and components are those necessary to assure: (1) The integrity of the reactor coolant preesure boundary, (2) The capcbility to shut down the reactor and maintain it in a safe shutdown i condition, or l (3) The capability to prevent or mitigate
- the consequences of accidents which I could result in potential offsite i exposures ccmparable to the guideline .
I exposures of 10 CFR Part 100. 36 Fed. Reg. 22,602 (1971) (emphasis added): see al'so id. at . 22,604. This definition of the " safety related" functions is
.he same as that in the final (and current) version of the rule, which is recognized as providing the basic definition of the " safety related" functions. See 38 Fed. Reg. 31,281 I (1973); 10 CFR Part 100, Appendix A, III(c).
Although the reference in paragraph (c) of the proposed rule to " structures, systems and ccmponents important to
_g. safety" was changed in the final. version to refer to "certain structures, systems and components," there was no indication in the Commission's discussion of changes between the proposed and final rules to indicate that this substitution represented a i l . change in scope. See 38 Fed. Reg. 31,279 (1973). In fact, the final rule added a reference in its purpose section to GDC 2, ! which applies to structures, systems and components "importan to safety," thereby once again equating " safety related" and "important to safety." In addition to defining "important to safety" in terms of the " safety related" definition, the proposed version of 10 CFR.aart 100, Appendix A, used the terms " safety related" and
' mportant Oc safety" nte rchange ably . Section 7:(a) of the I
proposed rule reiterated the definition o'f structuras, systems i and components important to safety quoted above and went on to say "(1]n addition to seismic loads, . . , loads shall be taken
; into account in the design of these safety related structures,
, systems and components." 36 Fed. Reg. 22,604 (1971) (emphasis added). Several other references to "these safety related structures , systems and components" appeared within the paragraph dealing with equipment "important to safety." Id.
Thus, the language in the proposed version of Part 100, Appendix A, made it abundantly clear that the terms "important i to safety" and " safety related" were interchangeable and equivalent.
D. 10 CFR, Part 72 Part 72 of 10 CFR, adopted in November 1980, provides another example of the equation of "important to safety" and
" safety related." This regulation states, in part, that ,
t applications for a license for an Independent Spent. Fuel Storage Installation (ISESI) shall describe the quality assurance program for the ISFSI. "The description of the quality assurance program shall identify structures, systems, and components important to safety and shall show how the ! criteria in Appendix B to Part 50 of this chapter will be
- applied to those safe
- y related compor.ents, systems and structures in a manner consistent with their importance to safety." 10 CFR*5 72.15(a)(14) (emphasis added). Although nce directly related to nuclear poner plants, the language of th s NRC regulation uses "important to safety" and " safety related"
! interchangeably. E. 10 CFR 4 50.54 As recently as January 1983, the Commiss on's - regulations. have treated important to safety" and " safety related d as equivalent. On January 10, 1983, the Commission l amended 10 CFR $ 50.54 providing that "the NRC Staff conducts ' extensive reviews'during the licensing process to ensure that l the applicant's QA program description satisfies 10 CFR Part i 50, Appendix B, . . . . Once the NRC has accepted it, the QA
program description becomes a principal inspection and enforcement tool in ensuring that the permit holder or licensee
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is in compliance with all NRC quality assurance requirements'- for protecting the public health and safety." 48 Fed. Reg. i 1826 (1983) (emphasis added). In other words, implementation
- of a quality assurance program satisfying Appendix B
, constitutes compliance with all NRC quality assurance 4
requirements, including, necessarily, GCC 1. Again, as noted
- 'above, Appendix B indisputably applies only to safety related i
structures, systems and components. L:us, this January 1983 regulation equates the scope of " safety related" in Appandix B { with "important to s'afety" in GDC 1. F. 10 CFR, Part 21 Part 21 of 10 CFR uses the term important to safety in 4 1 very limited say but even that limited use demonstrates the equivalence of the terms safety related and important to safety. Section 21.3(a)(3) notes that a "' basic component' includes design, inspection, testing, or consulting services important to safety . . . ." In discussing this portion of the regulation, the supplementary information published in the Federal Register with the regulation states that Part 21 covers
" responsible officers of firms and organizations supplying i
safety related components, including safety related design, testing, inspection and consulting services." 42 Fed. Reg. 28,892 (1977). Thus, this description evidently assumes that
i the use of the term important to safety in conjunction with design, testing, inspection and consulting services in i 21.3(a)(3) is meant to be synonymous with safety related. This interpretation is confirmed in NUREG-0302, Revision 1, which provides information concerning various aspects of 10 CFR Part 21. In explaining references to important to safety in Part 21,. the NUREG states in question and answer form: 521.3 states -- In all cases " basic ccmponent" includes design, inspection, testing, or consulting services
'important to safety...". Clarify the meaning of thi s statseent.
Res=onse: The broad scope of Section 206 activities of ccnstructicn, operation, , owning nnd sucplying in themselves include activities such as design, i consultation or ins =ection that are immortant to safety and are associated i with component hardware . . . . An . l organization may accomplish all of these activities in-house or may choose - to authorize others to do some of the safetv-related activities- e.g., , consultation, design, inscection or - tests, for it. When such contractual arrangements are made for safety-related services the ceganization accomplishing the service is within the scope of Part 21. NUREG-0302, Rev. 1, at 21.3(a)-5 (emphasis added). In addition, the NUREG expressly states that it applies only to safety related structures, systems and components:
l l l ! . . l l Does Part 21 apply to only " safety related" items?
Response
Yes. Part 21 applies to any defects and noncompliance which could create a substantial safety hazard in activities that are within the regulatory authority of the Nuclear Regulatory Commission; therefore only those items which are " safety related" are within o the scope of Part 21. 4 NUREG-0302, Rev. 1, at 21.3(a)-1 to -2. Thus, this NUREG confirms that in Part 21 "important to safety" and " safety related" are equivalent. Importantly, it also confirms that, in general, the NRC's regulatory authority is limited to safety i related items. This is consistent with the long-standing industry and NRC interpretation that impcrtant to safety means 4 safety related wherever the ter:1 appears in the NRC's regulations. 4 III. Regulatory Guides A. Regulatory Guide 1.105 Regulatory Guide 1.105, " Instrument Setpoints" (Revision 1, November 1976), provides an unmistakably clear indication that the NRC Staff considered important to safety and safety related to be equivalent. In this regulatory guide, i
" systems important to safety" are defined as:
i l those systems that are necessary to ensure ! (1) the integrity of the reactor coolant j pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe condition, or (3) the capability to prevent 1
. - - - - - - - - , - - , ,,_ _ .-- , - - , , . , ,,,,, , _ , , , , , _ , . . , , , _ _ , _ _ _ , ,, , , , _ ~ , , _ , ,
or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guideline exposures of 10 CFR Part 100, " Reactor Site Criteria." 4 Regulatory Guide 1.105, Rev. 1, at 1.105-2. Of course, this is precisely the definition of safety related structures, systems and components that appears in Appendix A to Part 100. Indeed, . it is the definition of safety related that was endorsed by Mr. Denton in his November, 1981, memorandum on the subject of safety classification. A proposed Revision 2 to Regulatory Guide 1.105, which was issued for comment in December, 1981, reiterates the NRC'3 intention to equate safety related and important to safety. This revision to the regulatory guide would endorse a documen: prepared by the Nuclear Power Plant Standards Committee of the Instrument Society of America (ISA) subject to several clarifications. One of the clarifications states: The term " safety-related instruments" is used throughout the ISA Standard. This term shall . be understood to mean " instruments in systems important to safety." The term " systems important to safety" is defined in the . Introduction of Appendix A to 10 CFR Part 50 as ". . . systems . . . that provide reasonable assurance that the facility can be operated withour. undue risk to the health and
. safety of the public."
Proposed Revision 2 to Regulatory Guide 1.105, at 2. Once again, the language of this regulatory guide expressly equates i l safety related with important to safety. l 1
Regulatory Guide 1.118 I Regulatory Guide l.ll8, " Periodic Testing of Electric Power and Protection Systems" (Ravision 2, June 1978), also explicitly equates important to safety and safety related.
, This regulatory guide adopts the definition of important to safety set out in Regulatory Guide 1.105, Revision 1, which, as noted above, makes it clear that the terms are equivalent.
Regulatory Guide 1.106 Regulatory Guide 1.106, " Thermal Overload Protection for Electric Motcrs on Motor-Operated Valves" (Revision 1, Ma;ch 1977), describes a method acceptable to.the NRC Staff for ' complying with certain regulatory requirements, including CDCs 1 and 4, with regard to the application of thermal overload devices for electric motors on motor operated valves. Both GDCs 1 and 4 apply to structures, system and components "important to safety." This regulatory guide, however, deals explicitly and exclusively with safety related motor operated valves to " ensure that the thermal overload protection devices will not needlessly prevent the motor from performing its safety related function." Thus, the clear implication of this i regulatory guide is that components important to safety under l , GDCs 1 and 4 are those components (in this case motor operated valves) which have been classified as safety related. l l
Regulatory Guide 1.151 Regulatory Guide 1.151, " Instrument Sensing Lines" (July 1983), states in the introduction of the regulatory guide: Section 50.34, " Contents of Applications; Technical Information," of 10 CFR Part 50 . . .
. requires, in part, that design criteria be established for structures, systems and components important to safety that will provide reasonable assurance that the facility can be operated without undae risk
, to the health and safety of the public. Criterion 1 . . . requires, in part, that structures, systems, and components ba erected (installed) to quality standards commensurate with the importance of the safety functions to be perfcc.ted. - Regulatory Guide 1.151, at 1. After stating the p.ertinent I regulatory requirements, the regulatory guide describes "a method acceptable to tne NRC staff for complying with the Commission's regulations with regard to the design and installation of safety-related instrument sensing lines in nuclear power plants." Id. (emphasis added). Here again, therefore, the NRC has . explicitly equated the terms. Significantly, the regulatory guide also addresses only two classes of instrument sensing lines: " safety related" and "non-safety related." l Consequently, the clear implication of this regulatory guide is that only two classifications of equipment are used in the design of nuclear. power plants and that by meeting certain standards for safety related equipment, regulations which deal with equipment important to safety are also met. This latter
i i point implies the equivalence of important to safety and safety related equipment. IV. NUREGs
. A. Safety Evaluation Reports , Safety Evaluation Reports for plants that have applied for construction permits or operating licenses are published as NUREG documents. In these NUREGs, the Staff rcutinely includes a number of statements equating safety related and important to safety. Rather than fecusing on specific plants and specific d
SERs, this section quotes from various SERs which cre typical 4 of SERs published by the Staff. I In discuscing General Design briterion 2 involving seismic design requirements. the Staff typically states in SERs that this GDC requires that nuclear power plant structures, systems and components important to safety be designed to withstand the effects of i earthquakes without loss of capability to perform their safety function. These plant features are those necessary to assure (1)
~ the integrity of the reactor coolant pressure boundary, (2) the capability to shutdown the
! reactor and maintain it in a safe shutdown condition, or (3) capability to prevent er
- mitigate the consgquences of accidents which could result in the potential offsite exposures comparable to 10 CFR 100 guideline l exposures.
1 Of course, the plant features defined above are those covered i in Appendix A of Part 100, which are the safety related set of structures, systems and components. Moreover, if appropriate,
'r 13 i
- the NRC Staff will conclude that a plant has been designed in.
compliance with Criterion 2 because classification of structures, systems and components conforms with guidance contained in Regulatory Guide 1.29, " Seismic Design Classification." This regulatory guide is recognized by .- industry and NRC as dealing with safety related structures, systems and components. . Another example from an SER deals with turbine i missiles. One SER notes that " General Design Criterion 4 , I requires that a nuclear power plant be designed against internally and externally generated missiles to assure no loss 4 of function or damage to safety-related equipment essential for a safe plant shutdown." General Design ~Crf.terion 4, of course, applies to " structures, systems, and compor.ents important to safety . . . ." Consequently, this NRC statement in a SER must ! be interpreted as explicit recognition of the equality of these two terms. Other SERs invite the same conclusion by discussing only the protection given to safety related structures when , assessing whether the plant is protected from turbine missiles as required by GDC 4. B. NUREG-0302, Revision 1 NUREG-0302, Revision 1, which deals with 10 CFR Part 21, is discussed in Section II.F above. l
19 I C. NUREG-0968 NUREG-0968 is the Safety Evaluation Report for the Clinch River Breeder Reactor (CRER). In discussing seismic design requirements for CRBR, the Staff states: CRBR Principal Design Criterion (PDC) 2, in part, requires that structures, systems, and components important to safety be designed to withstand the effects of. earthquakes without loss of capability to perfcem their safety functions. The earthquake for which these plant features will be designed is defined as the safe shutdown earthquake (SSE) in 10 CFR 100, Appendix A. The SSE is based upon an evaluation of the maximum earthquake potential and is that earthquake which produces the maximum vibratory ground motion for which structures, systems, and components imcortant to safety are designed to remain functional. NUREG-0968, at 3-34 (emphasis added). As already noted, the set of features designed to remain functional in the event of the safe shutdown earthquake are the safety related set of structures, systems and components, as defined in 10 CFR Part 100, Appendix A. V. Other NRC Licensing Documents l
-r A. I&E'Information Notice 83-41 (June 22, 1983)
This I&E Information Notice is entitled " Actuation of-t Fire Suppression System Causing Inoperability of Safety-Related Equipment" (emphasis added). The stated purpose of this notice is to " alert licensees to some recent experiences in which 1
l
- actuation of fire suppression systems caused damage to or inoperability of systems important to safetv" (emphasis j added.). Thus, as recently as June of this year, official NRC documents have used the terms important to safety and safety related interchtngeably. .
l i VI. Miscellaneous Industry Documents . j i A. Institute of Electrical and Electronics Engineers (IEEE) i J A number of industry groups have become aware of the inconsistent use of the term important to safety in some recent NRC documents, including the Denton memorandum. In response to these developments, the Nuclear Power Engineering Committee of IEEE wrote a letter to Mr. Robert 3. Minogue, Director of the office of Nuclear Regulatory Research, in May, 1982, making it clear that expansion of the scope of important to safety is
- l. contrary to'the long-standing interpretation of NRC regulations by both nuclear industry and the NRC Staff. The letter states .
that I (O]ver the years, the terminology of the General Design Criteria of Appendix A of 10 CFR Part 50 has been understood through l common usage to equate systems important to safety to safety related or safety systems. Repeated references within the General Design
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Criteria to preservation of the safety function being performed by " structures, systems, and components important to safety" enforces this equivalence of terms. l Letter from R.E. Allen to Robert B. Minogue, dated May 10, 1982 l
. _ - . - . _ _ _ _ = _ -
(attached), at 2. This letter also indicated that th'e Nuclear Power Engineering Connittee of I,EEE opposed the expansion of . I the term important to safety. J B. American National Standards Institute 'l 1 The Nuclear S'.:andards Board (of the American National 'l Standards Institute) Ad Hoc Committee on "Important to Safety" has made a recommendation to the full Nuclear Standards Board 1 of ANSI which is pertinent tc the definition of important to , safety. The Ad Hoc Committee's recommendation follows: 2 The current practice utill ing two major classifications, safety related and nonsafety related, for design, construction, testing and operation of, nuclear power plants is acceptable and appropriate. This has occurred with a general understanding and usage that the terms "Important to Safety" and
" Safety Related" are equivalent in meaning. The current practice has recognized that within the nonsafety related set, there are varying degrees
- of importance to safe and reliable operation. For many or most items of
; this nature, standards have been promulgated to guide design, construction, testing and operation.
. Even so, the NRC may determine there is a need, for licensing purposes, to identify a category of items, although nonsafety related, (that) are of more , importance to the safe and reliable operation of the plant than other nonsafety related items. If'so, the term "Important to Safety" should no,t i i be used.to designate this set of items - I because of the past history of equivalence to the term " Safety Related". To accly the term, "Important to Safety" across the body of regulations to a new set of items
would cause the term to become unclear as to the meaning of all current requiation and licensing commitments that stem therefrom. If this set of items is defined, it should be on a functional basis (e.g.,
'ANS-51.1 and ANS-52.1). Requirements in existing standards for such -
functions, that are unique to specific functions, should be used. Letter from Walter H. D'Ardenne to George L. Wessman, dated March 30, 1983 (attached) (emphasis added). This recommendation gives yet another unmistakable indication that the nuclear industry has equated the terms important to safety and safety related. s l l 9
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I 4 AMERICAN NUCLEAiSGCIETY STANDARDS COMMITTEE
' ' . ;g 5 7=-=^2 usa '::::;-litilif.
Tasma 22d5 March 30, 1983 George L. Wessman
. Chairman ANSI Nuclear Standards Board e Torrey Pines Technology P. O. Box 81508 San Diego, CA 92138
Dear George:
The Nuclear Standards Board Ad hoc Committee on "Important to Safety"The objective of the meeting was to rt: commend to NSB City. approach on "Important to Safety" that all standards writing organizations could follow. That recommended approach is attached and represents unanimous agreement of those attending the Ad hoc Committee Meeting. Also attached is the list of attendees at the meeting. < Sincerely, Y Valter H. D'Ardenne, Chairman Ad hoc Ccmmittee on Important to Safety ! WH0:pab: cal /J03304 Attachment
~
cc: G. F. Dawe, Jr. O. A. Campbell E. F. Dowling J. Ling J. Millman B. M. Rice R. E. Allen ' J. F. Cooper R. A. Szalay C. T. Zegers .
l l, . A0 HOC COMMITTEE ON IMPORTANT TO SAFETY RECOMMENDATION l The current practica utilizing two major classifications, safety related i and nonsafety related, for design, construction, testing and operation of l nuclear power plants is acceptable and appropriate. This has oc::urred withageneralunderstandingandusagethattheterms"Importantto Safety" and " Safety Related are equivalent in meaning. The current practice has recognized that within the nonsafety related set, there are varying degrees of importance to safe and reliable operation. For many . or most itans of this nature standards have been promulgated to guide - design, construction, testing, and operation. Even so, the NRC may determine there is a need, for licensing purposes, - to identify a category of itans, although nonsafety related, are of more importance to the safe and reliable operation of the plant than other nonsafety related items. If so, the term "Important to Safety" should "not be used to designata this set of items because of the past history of equivalence to the term " Safety Related". To apply the term, "Important to Safety" across the body of regulations to a new set of items would cause the term to become unclear as to the meaning of all current regulatior and licensing commitments that stas therefrom. If this. set of items is defined, it should be on a functional basis (e.g., ANS-51.1 and ANS-52.1). Requiiements in existing standards for l such functions, that are unique to specific functions, should be used. f 9 4 9 l l l l l l
ATTENDANCE LIST NAME ORGANIZATION . . Walter H. 0'Ardenne ANS George F. Dawe, Jr. Stone & Webster Engineering Ccrp. Donald A. Campbell ANS Edward F. Dowling IEEE June Ling - ASME John Millman ASME Bill M. Rice IEEE - George L. Wessaan ANSI - 1 J l . WO nah/rnime 4 l .
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. 888'3 8 M8 Rabjectt Tse of the Term "Issernene to 5sfsty" W. om,8=sa .
' ' * * * ~
g Seferences: 1) Proposed Invision 1 to Regulatory c;, m. am c Guide 1.89. Environmental W W ' O.o.s se71s su w e C'"*****" cacima of Electric Ed*==-we for J421296eDe Encisar Power Flants. February I M 2. SC.<. Ammates, pas l C. S. tenmuk 2) Proposed $371 Side 2 to RegtlatDty , cu w s s== =.-- ;c Calds 1.105. Instrument serpoista. .
',;*$h
, Decommer, 1981.
ami anz.aeos s.a.anere u: 4. _ m - 3) Draft lagulatory Caide (Task. IC 126-3). J.c. h omed Inscrimune sensing 1.snes, March.1382. sew = 4 u esa . m.
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%, 4) .%sarandsse free Barn 1d L Dentaa to
' e m a.coes All NER Personnel, Standard Definir4nna 1 sc 4.r.aio-e. san.e s,se for Connoely-t! sed Safety Classificacian !
2.a. n==== Taras, Noveedwr 20, 1981. !
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-cw . =c. sene 5) 10CFR50, hoposed Rule (47FR2573, (8*988 w 2 1/20/62) Environmental qualificattan st 7.h *.ai e a. c u.s sraen e. of Elmetric Equipment for Nuclear
= . e % w c ,,e,e Power I a s.
- seo :--a a
***t =am. *S isass A ===her of recent NEC documents have used the term m:5 2se staa "importsat to safety" in describing the scope of systests
,"*'"'******* and equipment to whie's the dccturent applias. Notable l
a ..us. s w e, , ecamples are the proposed Revision 1 of Iegulatory Guide 388 % s er o**.n 1.89 (Referenea 1), the proposed Ierision 2 of Regulatory aiua=f*8***' Caide 1.105 (Reference 2), and that draft Resulatory cuide . l on Instrument Sensing Lines (Task 1C 126-5) (Raference 3). SC *.susie.. n 4 v. J. 9. Ensus
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Mr. anbert 3. Midosse. Birector May 10, ISg2 i E1. M-=v Regulatory casmaissian 82-C-015 ) amference is unde to 19Cr1 Part 50 as the moorear of the terminology. Over the years, the tasainalogy of the General Sealgn~Critaria el
. Appendix A of 10cr1 Part So has been maderstned through commen usage to mouate systema important to safety to safety-related er safety systems.
The repascad refernaces within the Caneral Design Critaria en preservation ci the safety function heing perfonned by "arructures, systeam, and
-pa===sts important to safety" zeinfotees this ageimatense of terms. .
. Da current 3RC incentian in the mee of the term "important to safety" cppears to be to brandan the senpa of W- at addrassed to include apre .
than safety-related or safety systems. In an intnesal NEC 1memorena== (3efermace 4) Marold Dentos de. fined " safety-calated" as a sabeet of "important to safety". Broadening the usage of the term "important to s&ficty" to sacompass an wedafined set of systems. in addiziam to safety- , r31ated or safety systems, facreases confusion in the dialogue on current 3RC taquir===re/suidamee and creates se isomekahle situation. A clear nederstanding of the principles ferr detesmiaing that is included and what is not taciudad in " systems important to safety" is moedad. Rar exampic, Hegulatory Guide 3.145, instrumene setpuiets, receenved* the subetitution of " systems importsat to safety" for "=el-r-mafety-related". This suharitution of teres adds an unkanwn anseber of systems to the set of
, systems required tn meet the draft ISA steadmed.
The IZEE, through a Suelear Power Engineering Committae OTPEC) working group on atandards project PS27, is attempting to develop a methodology for ecsigning design criteria based on a system's icvel of importance to safety. l Although considerable programe has been made on the subject in the last year and a half. the methodology has et been developed to the point of being easily understood and usable. Unfortunately, the complextry of the subject peuvents the methodology, as currently developed, from being matformly interpretad and applied by individus1 usera. Ecrk is continuing on over-1:osing this deficiency. so that appitemtfon may be ennaistent frcui usar to
- maar and enforessent may be uniform from application to applicarden. The difficulty in producing this methodology underscores the seed for careful -
, choice of tar:minology so that a basis is established to previote ceazzan l, understanding and not to introduce additional confusion. Inicil the P827 methodology has passed through the IIEE review (consensus process and the term " systems 1sportant to safety" has' a comanonly understood meaning, it is recommanded that the NRC refrain from using thin tatz uithout -
. also including a clear definition of which systems are addressed. This is cxactly uhat was done in the development of the rule on equipment qualificati (Raference 5). Alternstively, comuzanly understood terms, such as safety-rela and terms defined in voluntary standards, such as safety systems, should be employed. If it appears necessary to address systess beyond the scope of the terms, then the additional systems should be clearly identified. j l
It is reconcended that the term " nuclear-safety-relsted" he retained in the proposed Revision 2 to Regulatory Guide 1.105 and the proposed Regulator, cuide en Instrument Sensing 1.ines (Task 1C 126-5) and that the term "i:sportas to safety" not be used in these documents.
.t .
~
Mr. Embert 1. Minogue. Director + May 10, I N 2 8.3. meclear assulatory Cammaisoism , 82-C-415 It is also rec ====nJad that the term " electric equipment important to amfety" be replaced by " Class 12 electric equipment" in the seccad para-
. graph of the increduction to the proposed Revisian I to Esgulacory Calde 1.31.
As an alternative ce these two racamusendatises, it is rechd that the general terms be replaced with a specific tahalatica of the systems /. s equipment to which the regulatory guide is applicable. . Similar treatment should be accorded other sBC regulatory documenca la the fur.ure. or encil the P827 met _"1T reaches consensus in the lamelaar powe rammunity.
. Yery truly yours, b
. E. Allen Chairman. NFEC
. ::EA/anh "
, cc: Paul C. Shewson l Coleman, Advisory Ccesittee on peactor Safeguards Harold R. Denton. Director
. Office of Nuclear Reactor Ragt!. scion Ed.ard C. Uensinger, Chief Inscrimentation athi control Branch office of Nuclear Reactor Regulacion l
I _ _ _ _ _ . _ _ . _ _ _ . . _ _ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ _ . . , - . . , _ _ _ - _ ._
i ATTACHMENT C
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Numerous recent events have taken place on the unjustified assumption that the Staff /Denton distinction between " safety related" and "important to safety" is correct. In light of the numerous examples cited in Attachment 3, however, these actions ignore the historical evaluat on of the terms and the long-standing interpretation and application of the NRC's regulations:
- a. The Commission approved a final rule on environ-mental qualification of electric components in January of this year. 48 Fed. Reg. 2729 (January 21, 1983). 'The rule, by its terms, is applicable to electric equipment "important to safety." That term includes safety related equipment performing the three safety functions defined in Part 100, .
Appendix A. (10 CFR 5 50.49(b)(1)). It also includes, however, nonsafety-related electric equipment whose failures under postulated environmental conditions could prevent satisfactory accomplishment of safety functions specificed
- in (Part 100, Appendix A} by the safety-related equipment.
10 CFR $ 50.49(b)(2). The important but subtle addition of the term important to safety in defining the scope of the rule and the addition of $$ (b)(2) and (3) were made in the last draft of the regulations, after the close of the public comment
1 1 1 . period. It is interesting to note that the scope of the rule could have been defined as electric equipment within the three categories listed in the rule ((b)(1), (b)'(2) and (b)(3)) without calling that equipment important to safety. Thus, this i last minute addition to the rule contravenes the historical use
- of the term important to safety without adding anything of substance to the rule. The principal result of its use in the environmental qualification context is that it creates substantial confusion about the meaning of the term.
- b. The Staff commissioned the Idaho National Engineering Laboratory to undertake a study of potential g
raded QA" requirements reaching substantially beyond the scope of Part 50, Appendix 3, and involving equipment important to safety. Identification and Ranking of Nuclear Power Plant S tructure s , Systems and Comconents, and Graded Quality Assurance Guidelines -- Draft (November, 1982) (EG&G-EA-6109).
This report received widespread criticism and has not been issued in final form. The widespread criticism reflects the difficulties utilities and the NRC Staff will encounter in l i trying to redefine the class of' structures,. systems and . components important to safety, if that term is ultimately given a broader meaning than safety related. Sigggficantly, the EG&G effort only addresses quality assurance requirements; the difficulties will be multipled if any new classification scheme considers, as it must, the impact on plants for each of the many places in the regulations where the term appears.
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- c. . Preliminary versions of a final ATWS rule have contained supplementary infermation . discussing the classification of ATWS related equipment. Some ATWS prevention and mitigation equipment will not be required to be " safety
, related," but must be classified "important to safety."l/
Given the nuclear industry's and the NRC's synonymous use of these terms, the rule has the potential to create substantial confusion. Utilities do not have a separate classification category of important to safety, nor are there any NRC i specified standards to be applied to such a category (if that category is assumed to be different from the safety related category). As with the Environmental Qualification rule, this use of the term i=portant to safety was not included in any of the proposed versions of the rule. Thus, the implications of changing the NRC's classification scheme have not been fully aired in the rulemaking.
- d. In the still-pending Shoreham case, docket 50-322 4
(CL), the Staff supported the argument of intervenors on the systems classification terminology. Although the Staff supported the acceptability of the Shoreham design, the Staff position on terminology was used by the intervenors to call , 1/ See Enclosure A to SECi-83-293 dated July 19, 1983. A ' table entitled " Guidance Regarding System and Equipment Specifications" indicates that certain equipment need not be safety related, but a footnote to the table states that " this ! equipment is in the broader class of structures, systems and compo.nents important to safety . . . . y - , _-- - % _ _, . 7 ,,,_._,,,,,_,.9,.-_,,y -4 . , , _ ,p.m.,. _.p,. .__,, , _ , , . . , , _ , ,,9 y_- %,m,__,__-.7. _
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-into question over a decade of design of the Shoreham plant.
This licensing case triggered a Differing Professional" Opinion (DPO) by James H.'Conran, a Staff witness at both Shoreham and TMI-1. The issue of "important to safety" has been raised-by intervenors in other cases, including Diablo Canyon, Byron and . Stabrook.
- e. Mr. Conran's DPO has recently been resolved (William T. Russell memorandum to Harold R. Denton, June 22, 1983; Harold R. Denton memorandum to Themis P. Speis, July 11, 1982) on a basis which includes proposals for a generic letter rolative to the "important to safety" concept. Mr. Russell's msmerandum twic'e stresses the presumption'that use of the term "important to safety" should impose no new regulatory 4
rcquirements. Whether that is, or can be, true, depends on the content of the generic letter which presumably will be issued in the near future. If that letter endorses a definition of "important to safety" that is inconsistent with its historical cquivalency to " safety related," then, contrary to the resolution of the Conran DPC and the Denton Memorandum, there * > will be new regulatory , requirements imposed on all nuclear power plants.
- f. The expanded definition of important to safety also i
tppears in generic letter 83-28, issued as a result of the Salsm incident. According to section 2.2.1.6, licensees and cpplicants must provide the NRC Staff with certain information l I l l
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regarding this category of equipment that is supposedly larger - than the safety related set. As already noted, utilites do not have, nor do the NRC's regulations require, such an expanded category. Similarly, statements in NUREG-1000, which also relate to the Salem incident, incorrectly assume that important to safety is a broader category than safety related. 9 I e 9 G
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October 27, 1983 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission ' Washington, D.C. 20555 Attention: Chief, Docketing and
- Service Branch Comments of the Utility Safety Classification Group on the ANPR f or the Backfittinc Rulemaking (48 Ted. Rec. 44217) -
~
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Dear Mr. Chilk':
The Commission published in the Federal Register an ad-vance notice of proposed rulemaking ,(ANPR) on the revision of the backfitting process for nuclear reactors, 48 Ted. Reg.
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. 44217 (September 28, 1983). This rulemaking would establish requirements fo; the long-term management of the NRC's process tar imposing new regulatory requirements for power reactors.
The notice invited interested persons to submit written com-ments and suggestions by October 28, 1983. This letter will provide the' comments, in response to the ANPR, of the Utility ,
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Safety Classification Group. t
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Although various members of the Utility Group, will sub-
- mit additional comments on this ANPR either individually or as
! members of other organizations interested in the backfitting l rulemaking, tIese ' comments are intended to focus on the rela-tionship between the safety classification issue and the l backfitting rulemaking. In particular, the safety classifica- - tion issue provides a useful example to consider in developing an appropriate definition for "backfitting." Other pertinent examples, such as the administrat,ive requirements contained in NUREG-0737, also demonstrate the need for the broad definition
~
of backfitting suggested in this letter. These bther examples i will not be addressed by the Utility Group but should be con-f . sidered in the rulemaking. \ l Utility Saf ety classification Group The Group is composed of 38 electric utility companies l that have among them over seventy nuclear reactors currently in l l operation or under construction. A list of the Utility Group's , members is attached. - The Utility Group's interest, and indeed its purpose of . existence, is the issue of the NRC Staff's efforts to change
.' certain definitions used in systems classification. The regu-latory terms " safety related" and "important to safety" have -
been used synonymously by industry and the NRC over many years of plant. design, construction, licensing and operation. ('
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. H e x r o x-k W12.1.x Mis Construction permits and operating licenses have been issued .
based on licensee commitments to and NRC acceptance of the syn-onymous use.of these terms. The Utility Group believes that recent NRC Staff, actions signal a sharp departure from this long-standing definition of the term "important to safety" to cover a much broader and undefined set of plant structures, ! systems and components than is covered by'the term " safety re-
, lated." The Utility Group's concerns have been set out in,de-tail in a letter from its counsel to William J. Dircks dated August 25, 1983. .
. The impetus for the NRC Staff's efforts to expand the definition of "important to safety" s,eems to be a desire to ex-i . , pand some measure of design and quality regulation beyond "safeIyrelated" equipment. It is important.to note that while
.- variations exist in the details of practice, industry as a whole has generally applied design and quality standards to non-safety related structures, systems and components in a man-ner co7,mensurate with the functions of such items in the ,over-l; i
- all saf ety and operation of the plant. The Utility Group is
- confident that these measures do adequately ensure that l non-safety related equipment will perform its intended fune-
! . tion.
I 4 5
1 H C.N T O N Sc W2 LLI AM S - Despite the existing measures applied to ncn-safety re . '- , lated structures, systems and components, redefining "important to safety" without proper review will have f ar-reaching, perva-
.. ~
sise consequences for licensing and general regulation of nu-clear plants, particularly for operating plants. Specifically, given the extensive use of the term "important to safety" in . the commission's regulations and staf f regulatory guides, NUREG documents and other licensing documents, as well as licensee
. submittels, the result of this sharp departure from the Isng-standing definition of this term would be a largely unexamined and perhaps unintended expansion of the scope of the above doc-uments. Consequently, the Group is intensely interested in Commission efforts to control the imposition of new regulatory requirements.
The Relationship of the safety Classification Issue to the Eackfitting Rulemaking Question 1.a of the ANPR asks, in essence, whether backfitting management measures should apply to proposed hard- . ware changes or whether the term should be more broadly defined to encompass other activities associated with a nuclear power plant. The Utility Group urges the Commission to define "backfitting" to' encompass any change in a segulatory require- , ment or its implementation which results in any change in the design, constru'ction, testing or operation of a nuclear power I*. _. __. ._. c .- - - - . _ _ _ _
1 H t:xTox & WILLI AMS plant 'f or which a construction permit or operating license has been issued. A narrower definition of "backfitting" would,only partially accomplish the rulemaking's goal of injecting ratio-nal management into the process of imposing new regulatory re-quirements. In the case of saf ety classification, the widespread use of the term "important to safety" throughout the Commis-sion's regulations, staf f regulatory guides, NURIG documents , and other licensing documents means that ahy change in the definition of "important to safety" would"have ramifications well beyond the imposition of new hardware iequirements. Such a change could, for example, affect such activities as quality
,- assurance programs, seismic and environmental qualification programs and training programs. Changes ir, these and other
) programs are c'ertain to entail extensive expenditures of utili- - j ty resources. Thus, at a minimum there is an impact that should be weighed against the corresponding benefits. More-
' over, because utility resources are finite, changes in such progra.bs may well result in a dilution or diversion of a utili-ty's resources with a potential corresponding decrease in safe-l ty. Consequently, it makes sense to give the term
- "backfitting" a broad interpretation to ensure that all aspects ,
of the imposition of new requirements, whether.the result of . new regulations 'or the clarification or interpretation of i l existing regulations, are effective'ly scrutinized.
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- li U .N T O N & WILLI AMS . ~ * '
The Utility Group also urges the Commission to .give a . broad interpretation to what is considered a "new requirement" in any revis,ed backfitting rule. Question 1.b. of the ANPR . asks whether the Commission's interim directions to the NRC Staff provide a useful approach. These interim directions de-fine a backfit as a proposed new staff position or a proposed change in an existing staff position. The Utility Group . believes that 'these directions should be expanded to include 4 instances in which the Staf f "c1,arifies" or " reinterprets" ex-isting staff positions or NRC regulations. The safety classi- ) l fication issue provides a good example of why this should be so.
~
The present issue was framed by a November 20, 1981 memorandum from NRR Director Harold Denton to all NRR person-
~
l nel. This memorandum which has never been circulated for pub-lic comment and which argues that the category "important to safety" is broader than "sa'fety related" (or " safety grade"), disclaims any intent to alter existing regulatory requirements. Although the Utility Group believes that the NRC Staff's effort - l . to expand the definition of "important to safety" is an attempt l to change the meaning of a regulatory term without benefit of rulemaking or other appropriate procedure, some Staff members do not agree. According to them it is merely a " clarification" of the defi[ition of important to safety. Despite the 6 ) e
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. H C NT o x Sc WILLI AM S disclaim,er and the characterization, revision of the de,finition of "important to safety" to make it a broader category than
" safety related" could have far-reaching, pervasive conse-quences for the ' licensing and general regulation of nuclear plants. Thus, clarifications of existing staff positions or new interpretations should be included within any definition of "backfitting."
We hope these comments prove helpf ul. We will be happy to provide further information if you wish., Sincerely yours, .
~
u&. b/% T.7.'E"11isf II F ' /. Donald P. Frwin , Anthony F. Earley, Jr. Counsel for titility safety Classification Group Attachment , cc: Chairman Nunzio J. Palladino -
, Commissioner James K. Asselstine Commissioner Frederick Bernthal .
Commissioner Victor Gilinsky
. Commissioner Thomas M. Roberts William J. Dircks Herzel H.E. Plaine, Esq.
j I e I (. l 1 I
L .- .
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UTILITY SAFETY CLASSIFICATION GROUP L .- ,. . Arkanas Power' & Light Co. (representing also Mississippi Power & Light, and Louisiana. Power & Light)
- Baltimore Gas & Electric Co.
Cincinnati Gas & Electric Co.
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Cleveland Electric Illuminating Co. Commonwealth Edison Co. Consolidated Edison Company of New York
- Consumers Power Co. ,
. Detroit Edison Co.
Florida Power Corp. - Florida Power & Light Co. Gulf States Utility Co. - Illinois Power Co. Long Island Lighting Co.. Nebraska Public Power District Niagara Mohawk Power Corp. !- Northeast Utilities Service Co. Northern States Power Co. * , Omaha Public Power District Pacific Gas & Electric Co. ! Pennsylvania Power & Light Co. . Public Service Company of Indiana Public Service Company of New Hampshire (representing also the Yankee Atomic Electric Power Company, Maine Yankee Atomic Power Co. 3
- and Vermont Yankee Nuclear Power Co.
Public Service Electric & Gas Co. . Rochester Gas & Electric Corp.
- Southern California Edison Co.
! Sacramento Municipal Utility District ! SNUPPS , (representing Uriion Electric Co., Kansas Gas & l Electric Co., Kansas City Power & Light Co., i and Kansas Electric Power Coop., Inc.) . Toledo Edison Co. Wisconsin Electric Power Co. Wisconsin Public Service Corp. l . 9-( . i i e
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pW %'o . o UNITED STATES
!
- 3 g ,j NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 .
cc 191983 T. S. Ellis, III, Esq.
. Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212
Dear tir. Ellis:
The Executive Director for Operations has asked me to respond to your letter of August 26, 1983, in which you express concern, on behalf of the Utility Safety Classification Group, over the NRC use of the , terms "important to safety" and " safety-related." Your concern appears to be principally derived from recent licensing cases in which the meaning of these terms in regard to NRC quality assurance requirements has been at issue, and my memorandum to NRR personnel of November 20, 1931. I agree that the use of these terms in a variety of contexts over the . past several years has not been consistent. In recognition o' *.his problem I attempted in my 1981 memorandum to NRR personnel to set forth definitions of these terms for use in all future regulatory documents and staff testimony before the adjudicatory boards. As you are aware, the position taken in that memorandum was that "important to safety" and
" safety-related" are not synonymous terms as used in Commission regulations applicable to nuclear power reactors. The former encompasses the broad scope of equipment covered by Appendix A to 10 CFR part 50. the General Design Criteria, while the latter refers to a narrower subset of thi: class of equipment defined in Appendix A to 10 CFR Part 100 Section VI(a)(i) and, more recently, in 10 CFR 50.49(b)(1). Based on such a distinction between these terms, it generally has been staff practice to apply the
- quality assurance requirements of Appendix B to 10 CFR Part 50 only to the narrower class of " safety-related" equipment, absent a specific regulation directing otherwise.
More importantly, however, this does not mean that there are no existing NRC requirements for quality standards or quality assurance programs for the broader class of nuclear power plant equipment which does not meet the definition of " safety-related." General Design Criterion 1 requires quality standards and a quality assurance program for all structures, systems and components "important to safety." These requirements, like those of Appendix B to 10 CFR Part 50, are "grsded" in that GDC-1 mandates the application of quality standards and programs " commensurate with the importance of the safety functions to be performed," and expressly allows the use of " generally recognized codes and standards" where applicable
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T. S. Ellis and sufficient. Occumentation and record keeping requirements for such
. equipment are likewise graded. Pursuant to our regulations, permittees or licensees are responsible for developing and implementing quality assurance programs for plant design and construction or for plant operation which meet the more general requirements of GDC-1 for plant equipment "important to safety," and the more prescriptive requirements of Apoendix B for " safety-related plant equipment. *
-This distinction between the terms "important to safety" and " safety-related" has been accepted in two recent adjudicatory decisions where -
the issue was squarely faced. In the Matter of Metropolitan Edison Company, et. al . (Three Mile Island Nuclear Station, Unit 1), ALAB-729, NRC (May 26,1983): In the Matter of Long Island Lighting Company (3Fo'reham Nuclear Power Station, Unit 1), LSP-83-57, NRC (September 21, 1983). Moreover, the Commission itself recognized and endorsed a distinction between the terms in promulgating the Seismic and Geologic Sitin
.VI(a)(1) and VI'a)g(2)
Criteria for Nuclear of Appendix Power A to 10 Plants CFR Part (see 100) andSection the 7 Environmental Qualification Rule (see Supplementary Infomation and
. 10 CFR 50.49(b)). Also, in preparing this response, members of the licensing staff and legal staff reviewed all of the material on this subject provided by your letter, and have also reviewed numerous other .
regulatory documents, including both staff and Commission issuances over the past several years in which the terms " safety-related" and "important to safety" are used. While it is apparent that some confusion continues to exist with regard to the distinction between the terms, the staff is convinced that the position it has previously taken remains correct. The final point which I considered in responding to your letter is the consistency of NRC staff practice over the years with our position on this issue, and the technical basis for that practice. While orevious staff licensing reviews were not specifically directed towards determining I whether in fact pennittees or licensees have implemented quality assurance l programs which adequately address all structures, systems, and components . important to safety, this was not because of.any concern over lack of
- regulatory requirements for this class of equipment. Rather, our practice I
was based upon the staff view that normal industry practice is generally
- acceptable for most equipment not covered by Appendix B within this class.
Nevertheless, in specific situations in the past where we have found , i that quality assurance requirements beyond normal industry practice were needed for equipment "important to safety," we have not hestitated in imposing additional requirements commensurate with the importance to , safety of the equipment involved. We intend to continue that practice. - l
. l l
T. S. Ellis We riote that in a more recent letter on this subject (comments dated October 27, 1983 on the Advanced Notice of proposed Rulemaking on Backfitting Requirements) you have stated that ... " industry as a whole has generally applied design and quality standards to non-safety related structures, systems and components in a manner comensurate I with the functions of such items in the overall safety and operation of the plant." The principal difference, then, between the NRC Staff position discussed above and that expressed in your letters appears to be your view that such actions by the industry are purely voluntary, with no regulatory underpinning; whereas, we have been and remain convinced that such actions are required by General Design Criterion 1. I want to make it very clear that NRC regulatory jurisdiction involving a safety matter is not controlled by the use of the tems such as
" safety related" or "important to safety."
A copy of your letters and this response are being sent to all pemittees and licensees for infomation. Sincerely,
. * -;:0 *4d&'
- M*.13 i Harold R. Denton, Director Office of Nuclear Reactor Regulation t
0 h i D i
i l Enclosure 2 Utility Safety Classification Group 501 18th Street, N.W. seae soo washlagten. D.C. 2 000 8 Technical Adviset: K MC, Inc. Legal Advisen Hunten & W:844 ems i l Mr. William J. Dircks U.S. Nuclear Regulatory Ccrnmission
, Maryland National Bank Building 7735 Old Georgetown Road Bethesda, MD 20814
Dear Mr. Dircks:
I am writing on behalf of the 35 metber Utility Safety Classification Group (Group) to supple: rent the Group's August 26 letter addressing the issue of safety classification. (See the attachment for a list of Group ne:Tbers.) That letter was prcepted by the understanding that the NRC staff was about to issue a generic letter which we believed would backfit a new definition to the term "irportant to safety." Our letter was intended to sumnarize the historical a;; plication of the term "important to safety" and to point out the potential adverse 1:: pacts of an "across-the-board" inposition of a regulatory definition that we saw but that the NRC staff might not have recognized. Because of our concerns, we requested that ' the generic letter not be issued. Since filing the August 26 letter, we have discussed the safety classification issue with members of the I&E and NRR staffs. We feel that these discussions have been beneficial. However, it is clear that no individual staff me:ter speaks for the entire NRC on this issue. NRR, I&E and the five regional offices each have a stake in the issue, and as yet the effort is not coordinated among the.m. Indeed, scrne offices seem to be noving in different directions. We believe that the safety classification issue is mainly one of ccxmunication in that the NRC staff is not aware of the nature and extent of utility quality and good engineering practices
' outside the safety related envelope. We feel that the issue might be resolved easily if the agency would identify an individual with sufficient authority located high enough in the NBC organization to speak for the staff in dealing with the Group on this issue.
Given the wn. unity to establish a dialogue with a designated contact within the agency, we believe that the Group will be able to work with the staff to achieve a resolution which will be acceptable to both the staff and the regulated industry. We understand that the staff's primary uncern involves the maintaining of apprcpriate design and quality standards for certain non-safety related equipnent throughout the operational life of the plant. It is our belief that nuclear power plant structuros, systems, and carponents are generally designed, - manufactured, constructed, operated, maintained, tested, repaired and replaced in a manner ccmnensurate with the role of each such structure, system and ccnponent in, the safe and reliable operation of the plant, and that is in the best interest of ec , r we r-mv . 1
1 each utility to do so. The proper reaintenance of even non-safety related equignent can irrpact the utility'r ability to generate safe, reliable and econcric electric Inwer. We believe that the application of good engineering practices and industry standards presently achieves a high level of performance throughout the utility industry. On the other hand, if the dialogue were to identify a safety concern in a non-safety related area, we believe that the NRC would have regulatory jurisdiction over the area. Indeed, fire protection, security and radioactive waste are exartples of.non-safety related areas within the NRC's broad regulatory authority under the Atmic Energy A:-t. - We hope you will consider favorably our request for a designated agency contact with whcra we can work to resolve generically this legitimate concern for safety, which we believe will be seen to be a non-issue. Until such a generic resolution is achieved, we believe it appropriate that the various tac offices (i.e., NRR, It.E and the regions) suspend consideration of this matter on individual dockets, at reactor sites, and in rulemaking proceedirgs, and that the safety classification issue be rem:ned frcm consideration before individual licensing and appeal boards. , Sincerely,
&m - WY&- -
Bruce L. Harshe Chairman, Utility Safety Classification Group cc: Mr. V. Stello Mr. H. Denton Mr. E. Case Mr. R. DeYoung Mr. J. Taylor i l e e 6
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FARCICIPANT 17IILITY OR3ANIZATIONS OF THE ITfILITY SAFEIY CIASSIFICATION GROUP Arkansas Power & Light Cb. (representing also Mississippi Power & Light, and Iouisiana Power & Light)
- Baltimore Gas & Electric Co.
Cincinnati Gas & Electric Co. Cleveland Electric Illuminating Co. Ccrmonwealth Edison Co. Consolidated Edison Cmpany of New York Consutrs Power Co. Detroit Edison Co. Florida Power Corp. Florida Power & Light Co. Gulf States Utilities Co. Illinois Power Co.
- Iong Island Lighting Co.
Nebraska Public Power District Niagara Mohawk Power Corp. Northeast Utilities Service Co. Northern States Power Co. Onaha Public Power District Pacific Gas & Electric Co. ! Pennsylvania Power & Light Co. t Public Service Capany of Indiana Public Servi Capany of New Hanpshire (representing also the Yankee Atcynic Electric Power Capany, Maine Yankee Atomic Power Co., and Vernent Yankee Nuclear Power Co.) Public Service Electric & Gas Co. Rochester Gas & Electric Corp.
- Southern California Edison Co.
Sacramento Municipal Utility District SNUPPS (representing Union Electric Co., Kansas Gas & Electric Co., Kansas City Power & Light Co., and raasas Electric Power Coop., Inc.) Toledo Edison Co. Wisconsin Electric Power Co. Wisconsin Public Service Corp. 1 I i
tnciosure a
/ 'o UNITED STATES
! NUCLEAR REGULATORY COMMISSION g* C WASHINGTON, D. C. 20555
%s ,,,< .p~ . & E 12s Mr. Bruce L. Harshe Chainnan, Utility Safety Classification Group
. 801 18th Street, N.W.
Suite 300 Washington, D.C. 20006
Dear Mr. Marshe:
The Executive Director for Operations has asked me to respond to your recent undated letter (postmarked November 23, 1983) written on behalf of the Utility Safety Classification Group which further addresses use of the term "important to safety." We note that your letter indicates that it is your belief that nuclear power plant structures, systems and components as a whole (including those which are important to safety) are designed, fabricated, operated, tested and maintained in a manner commensurate with the role of such features in the safe operation of the plant. Further, your letter indicates that should a safety concern in this area be identified, NRC would have regulatory jurisdiction. With regard to this latter point, you should note that our recent letter to Mr. Ellis, counsel of your group, makes it very clear that NRC regulatory jurisdiction involving a safety matter is not controlled by the use of terms such as " safety-related" and "important to safety," and our conclusion that, pursuant to our regulations, nuclear power plant permittees or licensees are responsible for developing and implementing quality assurance programs for plant design and construction or for plant operation which meet the more ;eneral requirements of General Design Criterion 1 for plant equipment "important to safety," and the more prescriptive requirements of Appendix B to 10 CFR Part 50 for " safety-related" plant equipment. While previous staff licensing reviews were not specifically directed toward determining whether in fact permittees or licensees have developed
' quality assurance programs which adequately address all structures, systems 1
and components important to safety, this was not because of any concern over the lack of regulatory requirements for this class of equipment. Rather..our practice was based upon the staff view that normal industry practice is generally acceptable for most equipment not covered by Appendix B within this class. Nevertheless, in specific situations in the past where we have found that quality assurance requirements beyond normal industry practice were needed for equipment "important to safety," we have not hesitated in imposing additional requirements commensurate with the importance of safety of the equipment involved. We intend to continue that practice. - ! - ///-//h I / #7NT q // uiv64 t w9 ,
. - - -. -. . _ . , . -w , -,...-,.r-- - , - . - - , - - - , , - -
Mr. B. L. Harshe The staff is interested in your conwents and views on whether further guidance is needed related to this issue. If you are interested in participating in a meeting with NRC to discuss this subject, plasse contact Mr. James M. Taylor Deputy Director Office of Inspection and Enforcement. Sincerely.
~
Original Signed By Harold R. Denton, Director
- Office of Nuclear Reactor Regulation
~
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DISTRIBUTION LIST FOR BOARD NOTIFICATION ASLB - Byron Units 1&2, Docket Nos. 50-454/455 ASLB/ALAB - Callaway Unit 1 Docket No. STN 50-483 ASLB - Catawba Units 1&2, Docket Nos. 50-413/414 ASLB/ALAB - Diablo Canyon Units 1&2, Docket Nos. 50-275/323 ASLB - Limerick Units 1&2, Docket Nos. 50-352/353
. ASLB - Midland Units 1&2, Docket Nos. 50-329/330 ASL3 - Perry Units IA2, Docket Nos. 50-440/441 ASLB - Scabrook Units 1&2, Docket Nos. 50-443/444 ASLB/ALAB - ASLB - Shoreham Unit 1. Docket No. 50-322 ASLB/ALAB - TMI-1 Docket No. 50-289 ASLB/ALAB - Waterford Unit 3 Docket No. 50-382 ASLB - Wolf Creek Unit 1, Docket No. 50-482 ASLB/ALAB - Zimmer Unit 1, Docket No. 50-358 Ms. Marjorie Aamodt John G. Cardinal, Esq. Eric A. Eisen, Esq.
- Mr. Vernon Adler Mr. Allen R. Carter Mr. Frederick Eissler Phillip Ahrens Esq. Doug Cassel, Esq. Charles W. Elliott, Esq.
Dr. George C. Anderson Mr. Brian Cassidy Peter S. Everett, Esq. . Mr. Robert L. Anthony A. Scott Cauger, Esq. Donald T. Ezzone, Esq. Ms. Elizabeth Apfelberg Kenneth M. Chackes, Esq. Mr. Jonathan D. Feinberg Maurice Axelrad, Esq. , Geraid Charnoff, Esq. Dr. George A. Ferguson Mr. Robert A. Backus Ms. Diane Chavez Mr. Zori G. Ferkin Edward M. Barrett, Esq. Myron M. Cherry, P.C. Lawrence R. Fisse, Esq. Mr. Edward G. Bauer, Jr. Mr. Donald E. Chick David S. Fleischaker, Esq. Charles Bechhoefer, Esq. Ms. Wanda Christy Mrs. Raye Fleming Lynne Bernabei, Esq. John Clewett, Esq. Luke B. Fontana Esq. Ms. Frieda Berryhill Hon. Peter Cohalan Dr. Harry Foreman J Mr. Samuel J. Birk Mr. David E. Cole Dr. Richard F. Foster E. Blake, Esq. Dr. Richard F. Cole Leon Friedman, Esq. Mr. Richard E. Blankenburg Troy B. Conner, Esq. Eleanor L. Frucci, Esq. Howard 1. Blau, Esq. Mr. Nicholas J. Costello Mr. John H. Frye III Douglas R. Blazey, Esq. Barton I. Cowan, Esq. R. K. Gad III, Esq. Peter B. Bloch, Esq. Dr. Frederick P. Cowan Steve J. Gadler, P.E. i Mr. Dan I. Bolef Philip A. Crane, Jr., Esq. Joseph Gallo Esq. Mr. Donald Bollinger T. J. Creswell Ms. Sandra Gavutis Ms. Louise Bradford Charles Cross, Esq. Arthur C. Gehr. Esq.
, Ms. Nora Bredes Edward L. Cross, Jr., Esq. Mr. Thomas M. Gerusky Lawrence Brenner, Esq. Gerald C. Crotty Esq. David H. Gilmartin, Esq.
Mr. Glenn 0. Bright Jordan D. Cunningham, Esq. Mr. Stewart M. Glass Mr. Earl Brown Ar. drew B. Dennison,'Esq. James P. Gleason, Esq. Herbert H. Brown Esq. Thomas G. Dignan, Jr . , Esq. Mr. Marc W. Goldsmith
. James E. Brunner, Esq. Dr. Reginald L. Gotchy Dr. John H. Buck Mr.
JamesJohn F. Doherty ,Esq.* Mr. Mark Gottlieb B. Dougherty, Carole H. Burstein, Esq. Ms. Jane Doughty Mr. Gary L. Groesch Martha W. Bush, Esq. Mr. Jay Dunkleberger Robert Guild, Esq. Mr. Ronald C. Callen Mr. Owen B. Durgin William J. Guste, Jr., Esq. Dr. Dixon Callihan Mr. Anthony F..Earley, Jr. Dr. Jerry Harbour Mr. Calvin A. Canney Gary J. Edles, Esq. Mr. Thomas H. Harris 1
DISTRIBUTION LIST FOR BOARD NOTIFICATION e ASLB - Byron Units 1&2, Docket Nos. 50-454/455 ASLB/ALAB - Callaway Unit 1 Docket No. STN 50-483
'ASLB - Catawba Units 182, Docket Nos. 50-413/414 ASLB/ALAB - Diablo Canyon Units 1&2, Docket Nos. 50-275/323 !
ASLB - Limerick Units 1&2, Docket Nos. 50-352/353 ; ASLB - Midland Units 1&2, Docket Nos. 50-329/330 ASLB - Perry Units 1&2, Docket Nos. 50-440/441 ASLB - Seabrook Units 1&2, Docket Nos. 50-443/444 i ASLB/ALAB - Shoreham Unit 1, Docket No. 50-322 ASLB/ALAB - THI-1, Docket No. 50-289 - ASLB/ALAB - Waterford Unit 3, Docket No. 50-382-ASLB - Wolf Creek Unit 1, Docket No. 50-482 ASLB/ALAB - Zimmer Unit 1, Docket No. 50-358 Mr. Robert J. Harrison . Terry Lodge, Esq. William L. Porter, Esq. Mr. Bruce L. Harshe Karen E. Long, Esq. Sen. Robert L. Preston Samuel A. Haubold, Esq. Mr. Harold Lottman Dr. Paul W. Purdom Mr. Wayne hearn Angus Love, Esq. Dr. Lawrence R. Quarles W. Peter Heile, Esq. Dr. Emeth A. Luebke Ms. Diana P. Randall Donald L. Herzberger, MD. Mr. Fred Luekey Mr. Paul Rau Ms. Susan Hiatt Steven Lewis, Esq. . John G. Reed Mr. Timothy S. Hogan, Jr. Mr. Angie Machiros Ms. Marjorie Reilly l Ms. Beverly Hollingworth Mr. John Marrs Harold F. Reis, Esq. l Dr. Frank F. Hooper Mr. Wendell H. Marshall ' W. Taylor Reveley III, Esq. Helen Hoyt Esq. David Martin, Esq. Joel R. Reynolds, Esq. Mr. Richard B. Hubbard Mr. Robert Martin Dr. Peter F. Riehm Mr. Henry D. Hukill Michael W. Maupin, Esq. Mr. Jesse L. Riley Sen. Gordon J. Humphrey Michael McBride, Esq. Ken Robinson, Esq. Mrs. Phillip B. Johnson Mr. Brian McCaffrey Mr. Frank R. Romano Dr. W. Reed Johnson J. Michael McGarry,III, Esq. Alan S. Rosenthal, Esq. Dr. Walter H. Jordan Mr. Patrick J. McKeon Ms. Jacqueline I. Ruttenberg William S. Jordan,III,Esq. Mr. Edward F. Meany Ms. Mary Ellen Salava Mr. James R. Kates Janine Migden, Esq. Mr. Alfred Sargeant Frank J. Kelley, Esq. Michael I. Miller, Esq. Mr. James 0. Schuyler James L. Kelley, Esq. Pro. William H. Miller Cherif Sedky, Esq. Mr. Chauncey Kepford Thomas S. Moore, Esq. Ralph Shapiro, Esq. Janice E. Kerr, Esq. William J. Moran, Esq. Mr. Steven C. Sholly Dr. Jerry R. Kline Dr. Peter A. Morris Mr. Frederick J. Shan Christine N. Kohl, Esq. ' Ms. Pat Morrison Jo Ann Shotwell, Esq. Stepher B. Latham, Esq. Bruce Norton, Esq.
- Ms. Barbara Shull James A. Laurenson, Esq. Dr. Hugh C. Paxton ' Jay Silberg, Esq.
Ms. Jane Lee Mr. Spence Perry . Mr. Gordon Silver > C. Edward Peterson, Esq.* 1 Dr. J. Venn Leeds, Jr. John M. Simpson, Esq. Mr. Howard A. Levin Ms. Roberta C. Pevear Ms. Mary Sinclair John Levin, Esq. Ms. Gail Phelps Ivan W. Smith, Esq. Mr. Marvin I. Lewis Mr. Samuel H. Porter Mr. Jeff Smith , Ian Douglas Lindsey, Esq. William C. Potter, Jr. , Esq. Mr. C. W. Smyth Mr. Gustave A. Linenberger Carol S. Sneider, Esq. 2
- .. - - - . . ~ - = < . ~ a-- - %.-wi..-
DISTRIBUTION LIST FOR BOARD NOTIFICATION ASLB - Byron Units 1&2, Docket Nos. 50-454/455 ASLd/ALAB - Callaway Unit 1, Docket No. STN 50-483 ASLB - Catawba Units 182, Docket Nos. 50-413/414 , ASLB/ALAB - Diablo Canyon Units 1&2, D3cket Nos. 50-275/323 ASLB - Limerick Units 1&2, Docket Nos. 50-352/353 ASLB - Midland Units 1&2, Docket Nos. 50-329/330 ASLB - Perry Units 1&2, Docket Nos. 50-440/441 ASLB - Seabrook Units 1&2, Docket Nos. 50-443/444 ASLB/ALAB - ASLB - Shoreham Unit 1, Docket No. 50-322 ASLB/ALAB - TMI-1, Docket No. 50-289 = ASLB/ALAB - Waterford Unit 3, Docket No. 50-382 ASLB - Wolf Creek Unit 1, Docket No. 50-482 ASLB/ALAB - Zimmer Unit 1, Docket No. 50-358 - Ms. Barbara Stamiris Brentwood Bd of Selectmen ACRS Members Mayor Howard Steffen Director, PA Emergency Dr. Robert C. Axtmann Malcolm Stevenson, Esq. Management Agency Mr. Myer Bender Michael J. Strumwasser,Esq. Division of Consumer Counsel Dr. Max W. Carbon Robert J. Sugarman, Esq. c/o Mr. Barry S. Zitser Mr. Jesse C. Ebersole David C. Thomas, Esq. MHB Technical Associates Mr. Harold Etherington George F. Trowbridge, Esq. Palmetto Alliance Dr. William Kerr Dr. Mauray Tye , Region III, USNRC Dr. Harold W. Lewis Paul C. Valentine, Esq. Town Manager's Office Dr. J. Carson Mark Ms. Anne berge Amesburg, MA Mr. William M. Mathis Dr. Bruce von Zellen Town of North Hampton, NH Dr. Dade W. Moeller Mr. Robert F. Warnick Dr. David Okrent Deborah Webb, Esq. Dr. Milton S. Plesset Ms. Ellyn R. Weiss Atomic Safety and Licensing Mr. Jeremiah J. Ray Mr. David Wersan Board Panel Dr. Paul C. Shewmon Mr. Joseph H. White III Atomic Safety and Licensing Dr. Chester P. Siess Mr. James Wiggins Appeal Panel Mr. David A. Ward Howard A. Wilber, Esq. Docketing & Service Section Ben Wiles, Esq. Document Management Branch Mr. Donald R. Willard Frederick C. Williams, Esq. 1 Harry M. Willis, Esq. Richard P. Wilson, Esq. Daniel D. Wilt. Esq. John F. Wolf, Esq. Sheldon J. Wolfe, Esq. j
. John D. Woliver, Esq.
Mr. Robert G. Wright Ms. Phyllis Zitzer 3
.c , -- - -
DN 84-011 Branch Service lists Page 1 RYRON
= Mr. Dennis L. Farrar Mr. William Kortier Mr. Edward R. Crass Mr. Julian Hinds CALLAWAY Mr.' D. F. Schnell Mr. J. E. Birk Mr. John Neisler Mr. Donald W. Capore Mr. James G. Keppler CAT"AWBA Mr. H. B. Tucker .
North Carolina MPA-1 Mr. F. J. Twogood Mr. J. C. Plunkett, Jr. Mr. Pierce H. Skinner North Carolina Electric Membership Corporatinn Saluda River Electric Cooperative, Inc. Mr. Peter K. VanDoorn Mr. James P. O'Reilly 6 s e D 4
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BN 84-011 Branch Service Lists - Page 2 DIABLO CANYON Mr. Malcolm H. Furbush Resident Inspector /Diablo Canyon NPS Dr. William E. Cooper - Mr. W. C. Gangloff Mr. Owen H. Davis Dr. Jose Roesset LIMERICK
- i. Honorable Lawrence Coughlin Roger B. Reynolds, Jr.', Esquire
- l Frederic M..Wentz Eugene J. Bradley Mr. Vincent Boyer Mr. Karl Abraham Mr. Suresh Chaudhary Joseph H. White III Director, Pennsylvania Emergency Maragenent Agency, PA Martha W. Bush, Esa.
Steven P. Hershey, Esq. Mr. J. T. Robb, N2-1 Governor's Office-of State Planning and Development, PA Department of Environmental Resources, PA Chairman, Board of Supervisors of Limerick Township U.S. Environmental Protection Agency, PA MIDLAND Mr. J. W. Cook Stewart H. Freeman Ms. Julie Morrison , Mr. R. B. Borsum Mr. Don van Farrowe U. S. NRC Resident Inspector's Office # Mr. Paul A. Perry Mr. Walt Apley Mr. James G. Keppler r Mr. Ron Callen Dr. Steven J. Poulos ,. Billie Pirner Garde 4 P. C. Huang Mr. L. J. Auge - Mr. Neil Gehring Mr. I. Charak Clyde Herrick Mr. Patrick Bassett , 1 l L I-
.- .- -- a- . :. : --
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I BN 84-011 Branch Ssrvice Lists - Page 3 PERRY Mr. Murray R. Edelman Donald H. Hauser, Esa. Resident Inspector's Office Mr. i lames G. Keppler
< SEABROOK Bruce Reckley , Diane Curran, Esc.
Jo Ann Shotwell, Esc. D. Pierre G. Cameron, Jr. , Esa. Regional Administrator - Region 1 E. Tupper Kinder, Esa. Resident Inspector John DeVincentis A. M. Ebner Stephen D. Floyd Diana P. Randall Letty Hett Anne Verge Angie Machirns Rosemary Chasman Nicholas D. Lewis I Honarable Richard Sullivan Donald E. Chick i Alfred V. Sargent Owen B. Durgin Guy Chichester SHOREHAM Mr. M. S. Pollock
-Energy Research Group, Inc.
i Mr. Brian McCaffrey i Honorable Peter Cohalan David Gilmartin Ezra I. Bialik
,- Shoreham Resident Inspector-Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esa. Mr. James Rivello Dr. M. Stanley livingstone Gerald C. Crotty, Esq.
.mp 4 , , + g, - -
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BN 84-011 Branch Service Lists - Page 4 i WATERFORD R. S. Leddick F. J. Drummond D. B. Lester
- Stephen M. Irving, Esq.
Resident Inspector /Waterford NPS D. C. Gibbs Regional Administrator - Region IV WOLF CREEK s Mr. Glenn L. Koester Mr. Nicholas A. Petrick , Jay Silberg Esa. ' Mr. Donald T. McPhee Ms. Mary Ellen Salava A. Scott Cauger Mr. Scott Schum Mr. Robert M. Fillmore Terri Sculley Ms. Wanda Christy Eric A. Eisen, Esq. C. Edward Peterson, Esq. Johm M. Simpson, Esq. Mr. John T. Collins Mr. Joe Mulholland Mr. James G. Keppler Brian P. Cassidy Three Mile Island Mr. R. J. Toole Board of Directors, P. A. N. E.
; J. B. Lieberman, Esa.
ANGRY /TMI PIRC Earl B. Hoffnan Union of Concerned Scientists l Name i Union of Concerned Scientists ' l Nane ! Mr. Gustave A. Linenberger, Jr. , ASLB l Christine N. Kohl, Esq., ASLAB Michael McBride, Esq., Leboeuf, Lamb, Leiby & McRae r Ivan W. Smith, Esq., Chairman, ASLR - l Mr. E. G. Wallace
- Ms. Virginia Southard Mr. David D. Maxwell Regional Radiation Representative ."
EPA, Region III Mr. Richard Conte, Snr Res. insp. (THI-1) 4 i G. .-
E l i BN'84-011 Branch Service Lists - Page 5 TMI (cont'd) General Counsel, FEMA Karin W. Carter, Esc. Dauphin County Office Emergency Preparedness Ms. Lennie Prough, USNRC, TMI-Site
. Governor's Office of State Planning & Develnpment, PA Dr. David Hetrick
- Dr. James Lamb ZIMMER V
Mr. J. Willians, Jr. Mr. Gregory C. Ficke . W. Peter Heile, Eso. Mr. John E. Dolan George E. Pattison, Esq. Mr. Waldman Christianson Mr. John Youkilis Mr. James G. Keppler Edward R. Schweibinz Mr. Robert Burger Mr. James P. Fensternaker t 1 4 e
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~, \ UNITED STATES
! % NUCLEAR REGULATORY COMMISSION
; e ,
wAswmoroN, D. C. 20065
%- ,/ January 24, 1984 -
Docket Nos.: 50-41 50-312 MEMORANDUM FOR: Chainnan Palladino Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine Comissioner Bernthal . FROM: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
BOARD NOTIFICATION 84-013: TDI RESPONSE TO NRC QUESTIONS CONCERNING TRANSAMERICA DELAVAL EMERGENCY DIESEL GENERATORS In accordance with the procedures for Board Notifications, the following information is being provided directly to the Comission. The appropriate boards and parties, for all facilities with TDI diesel generators, are being informed by a copy of this memorandum. This'information, which supplements that provided in Board Notifications 83-160 and 83-160a, is relevant to all facilities that have diesel generators manufactured by TDI, including Rancho Seco, which is before the Comission, and Grand Gulf (an uncontested case), which is scheduled to come before the Concission for full power authorization in the near future. On December 1, 1983, the NRC staff sent a list of questions (Enclosure 1) to TDI regarding the design and fabrication of diesel generators it had supplied for nuclear service. TDI responded en December 16, 1983 (Enclosure 2). The
! staff will review this response as part of its overall assessment of the reliability of TDI diesel engines.
r 1 k d fr1 G. E sennut, Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosures:
- 1. Letter #rce T. Novak (NRC) tc C S. Matthews (TDI), dated 12/1/83
- 2. Letter from C. S. Matthews (TDI) to A T. Novak (NRC) dated 12/16/83 ,
_ _ _ ~ , cc: See next pace ' i f I i
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. 1 cc: SECY (2) -
OPE OGC , EDO ASLB FOR: Shoreham 50-322 (Brenner, Ferguson, Morris, Laurenson, Kline, Shon) y Perry 50-440/441 (Bloch, Bright, Kline) Comanche Peak 50-445/446 (Bloch, Jordan, McCollom) - Midland 50-329/330 (Bechhoefer, Cowan, Harbour) ~ Catawba 50-413/414 (Kelley, Purdom, Foster) ASLAB FOR: Shoreham 50-322 (Rosenthal Edles, Wilber) Rancho Seco 50-312 (Rosenthal, Buck, Kohl) ; i
~ ,
DISTRIBUTION LIST FOR BOARD NOTIFICATION , , ASLB -Catawba Units 1&2 Docket Nos. 50-413/414 Dr. Peter F. Riehm ASLB -Comanche Peak Units 1&2, Docket Nos. 50-445/446 Mr. Jesse L. Riley i ASLB -Midland Units 1&2, Docket Nos. 50-329/330 Ken Robinson, Esq. ! ASLB -Perry Units 1&2, Docket Nos. 50-440/441 Alan S. Rosenthal, Esq.
- ASLB/ALAB -Rancho Seco Nuc Gen Station Docket No. 50-312 Cherif Sedkey, Esq.
ASLB/ALAB -Shoreham Unit 1, Docket No. 50-322 Ralph Shapiro, Esq. '~ Mr. Frederick J. Shon Jay Silberg, Esq. Martin B. Ashare, Esq. Mr. Marc W. Goldsmith Ms. Mary Sinclair Edward M. Barrett, Esq. Robert Guild, Esq. Mr. Lanny Alan Sinkin Thomas A. Baxter, Esq. Dr. Jerry Harbour Mr. Jeff Smith Charles Bechhoefer Esq. Mr. Bruce L. Harshe Ms. Barbara Stamiris
. Ms. Lynne Bernabei Samuel A. Haubold, Esq. Mr. Robert G. Taylor Howard L. Blau Esq. Mr. Wayne Hearn Howard A. Wilber, Esq.
Peter B. Bloch, Esq. Ms. Susan Hiatt Mr. Donald R. Willard Ms. Nora Bredes Dr. Walter H. Jordan Frederick C. Williams, Esq. Lawrence Brenner, Esq. David S. Kaplan, Esq. Richard P. Wilson, Esq. Mr. Glenn 0. Bright
. Mr. James R. Kates Herbert H. Brown, Esq. Frank J. Kelley, Esq. .
James E. Brunner, Esq. James L. Kelley, Esq. Dr. John H. Buck Dr. Jerry R. Kline MHB Technical Associates Mr. Ronald C. Callen Christine N. Kohl, Esq. Palmetto Alliance John G. Cardinal. Esq. Stephen B. Latham, Esq. Gerald Charnoff, Esq. James A. Laurenson, Esq. Myron M. Cherry, p.c. Dr. J. Venn Leeds, Jr. Atomic Safety and Licensing John Clewett, Esq. Mr. Howard A. Levin Board Panel Hon. Peter Cohalan Steven Lewis, Esq. Atomic Safety and Licensing Dr. Richard F. Cole Terry J. Lodge, Esq. Appeal Panel Mr. John T. Collins Karen E. Long, Esq. Docketing & Service Section Barton Z. Cowan, Esq. Dr. Emeth A. Luebke Document Management Branch Dr. Frederick P. Cowan Mr. Wendell H. Marshall Mr. T. J. Creswell Mr. Brian McCaffrey Gerald C. Crotty, Esq. Dr. Kenneth A. McCollom James B. Dougherty, Esq. J. Michael McGarry III,Esq. ACRS Members
. Mr. Jay Dunkleberger Janine Migden. Esq. Dr. Robert C. Axtmann Anthony F. Earley, Jr, Esq. Marshall E. Miller, Esq. Mr. Myer Bender Gary J. Edles, Esq. Michael Miller, Esq. Dr. Max W. Carbon Mrs. Juanita Ellis Dr. Peter A. Morris Mr. Jesse C. Ebersole Christopher Ellison, Esq. Chris Nolin Mr. Harold Etherington Peter S. Everett, Esq. Fabian G. Palomino Dr. William Kerr Donald T. Ezione. Esq. Spence W. Perry, Esq. Dr. Harold W. Lewis Mr. Jonathan D. Feinberg William L. Porter, Esq. Dr. J. Carson Mark Dr. George A. Ferguson William C. Potter, Jr..Esq. Mr. William M. Mathis Dr. Richard F. Foster David J. Preister, Esq. Dr. Dade W. Moeller Leon Friedman, Esq. Dr. Paul W. Purdom Dr. David Okrent Eleanor L. Frucci, Esc. Mr. paul Rau Dr. Milton S. Plesset '
Steve J. Gadler, P.E. James S. Reed, Esq. Mr. Jeremiah J. Ray Mr. R. J. Gary Harold F. Reis. Esq. Dr. Paul C. Shemon Stewart M. Glass, Esq. W. Taylor Reveley III,Esq. Dr. Chester P. Siess Mr. Jesse L. Riley Nicholas S. Reynolds Esq. Mr. David A. Ward - i 1 i
- l l
CATAWBA (for RNs) I
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tir. H. B. Turker. Vice Presidrnt l Nuclear Production Department ' Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 cc: North Caroline MPA-1 "- P.O. Box 95162 Raleigh, North Carolina 27625 Mr. F. J. Twooood Power Systems Division Westinghouse Electric Corp. P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. J. C. Plunkett, Jr. NUS Corporation 2536 Countryside Beulevard Clearwater, Florida 33515 Mr. Pierce H. Skinner Route 2, Box 179N York. South Carolina 29745 North Carolina Electric Menbership Corp. 3333 North Boulevard P.O. Box 27306 Raleich, North Carolina 27611 Saluda River Electric Coocerative, Inc. 207 Sherwood Drive Laurens, South Carolina 29360 Mr. Peter K. VanDenrn Route 2, Box 179N York, South Carolina 29745 - James P. O'Reilly, Regional Administrater U.S. Nuclear Regulatory Cornission, Reginn 11 101 Marietta Street, Suite ?100 Atlanta, Georgia 30303 e .
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. l COMANCliE PEAK Spencer C. Relyea. Esq. ..
Worsham, Forsythe & Sampels 2001 Bryan Tower Dallas, Texas 75201 Mr. Homer C. Schmidt Manaoer - Nuclear Services Texas Utilities Services, Inc. ~. 2001 Bryan Tower Dallas, Texas 75201 Mr. H. R. Rock Gibbs and Hill Inc. , 393 Seventh Avenue ' New York, New York 10001 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 O i l i l l l
l MIDLAND (For BNs) .
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Mr. J. W. Cook - Vice President Consur.ers Power Company 1945 West Parnall Road Jackson, Michigan 49201 cc: Stewart H. Freeman James G. Kepoler, Regional
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Assistant Attorney General Administrator State of Michigan Environmental U.S. Nuclear Regulatory Commission, Protection Division Region III 720 Law Buildino 799 Roosevelt Road Lansing, Michigan 48913 Glen Ellyn, Illir:ois 60137 Ms. Julie Morrison Mr. Ron Callen Midland Daily News Michigan Public Service Commission ' 124 Mcdonald Street 6545 Percantile Way Midland, Michigan 48640 Lansing, Michicen 48909 Mr. R. B. Borsun Geotechnical Engineers, Inc. Nuclear Power Generation Division ATTN: Dr. Steven J. Poulos Babcock & Wilcox 1017 Main Street 7910 Woodmont Avenue, Suite 220 Winchester, Massachusetts 01890 Bethesda, Maryland 20814 - Billie Pirner Garde Mr. Don van Farrowe, Chief Director, Citizen- Clinic Division of Radiological Health for ' Accountable Government i Department of Public Health Government Accountability Pro.iect P. O. Box 33035 Institute for Pnlicy Studies La'nsing, Michigan 48909 1901 Oue Street. N.W. l!ashington, D. C. 20:39
- U.S. Nuclear Regulatory Commission Resident Inspector's Office Connander, Naval Surface Weapnns Ctr.
Route 7 ATTN: P. C. Huang Midland, Michigan 48640 White Oak Silver Sprina, Marylar.d 20910 Mr. Paul A. Perry, Secretary Consumers Power Comeany Mr. L. J. Auge. Paaace-212 W. Michigan Avenue Facility Design Enoineering Jackson, Michigan 49201 Energy Technolooy Eng'neering Center P. O. Box 1449 Mr. Walt Apley Canoga Park, Californi a 91304 c/o Mr. Max Clausen Battelle Pacific North West Labs Mr. Neil Gehrino Battelle Blvd. U.S. Corps of Engineers SIGMA IV Building NCEED - T Richland, Washinoton 99352 7th Floor 477 P.ichigan Avenue l Detroit, Michiorn 48226 4 l 1
t Mr. J. W. Cnok 2 cc: Mr.1. Charak, Manager - -- HP.C Assistance Proiect Argonne National Laboratory 9700 South Cass Avenue Argonne, Illinois 60439 ATTN: Clyde Herrick - Franklin Research Center 20th & Race Streets Philadelphia, Pennsylvania 19103 Mr. Patrick Bassett Energy Division i Nnrwest Bank Minneapolis, N.A. ~ 8th and Marcuette Minneapolis, Minnesota 55479 4 e s 9 1 1 l 0
1 l , o i PERRY Mr. Murray R. Edelman . Vice President, Nuclear Group ';
- The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Dcnald H. Hauser, Esq. -'
The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office
- U. S. Nuclear Regulatory Commission Parmly at Center Road L
Perry, Ohio 44081 Mr. James G. Keppler U. S. Nuclear Regulatory Commission Region III . 799 Roosevelt Road Glen Ellyn, Illinois 60137 e j e l l 1
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Rancho Seco . Sacramento County .. . Board of Supervisors -
' 8?7.7th Street, Room 424 Sacramento, California 95814 Mr. John 8. Martin, Regional Administrator ,.
U.S. ?!uclear Regulatory Commission Regien V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Regional Radiation Representative EPA Region IX San Francisco, California 94111
!!r. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue
. Bethesda, Faryland 20814 Helen Hubbard P. O. Box 63 Sunol, California 94586 Ms. Eleanor Schwartz California State Office 600 Pennsylvania Avenue, S.E., Rm. 201 '
Washington, C.C. 20003 Resicent Inspector / Rancho Seco c/o U.S.N.R.C. 14410 Twin Cities Road Herald, CA 95638 Joseph 0. Ward, Chief Radiolooical Health Branch State Department of Health Services i 714 P Street, Office Building #8 Sacramento, California 95814
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l
. l SHOREHAM . . . . .
Mr. M. S. Pollock Vice President - Nuclear Long Island Lighting Company I 175 East Old Country Road ' Hicksville, New York 11801 I cc: David Gilmartin, Esquire Ezra I. Bialik, Esquire 1 Suffolk County Attorney Assistant Attorney General County Executive / Legislative Bldg. Environmental Protection Bureau Veteran's Memorial Highway New York State Department of Law Hauppauge, New York 11788 2 World Trade Center
. New York, New Y0rk 10047 '
Resident Inspector Lawrence Coe Lanpher, Esquire Shoreham NPS, U.S. NRC Kirkpatrick, Lockhart, Hill, P. O. Box B Christopher & Phillips Rocky Point, New York 11778 1900 M Street, N.W. Washington, D. C. 20036 Energy Research Group, Inc. Karla J. Letsche, Esquire 400-1 Totten Pond Road Kirkpatrick, Lockhart, Hill, Waltham, Massachusetts 02154 Christopher & Phillips 1900 M Street, N.W. Washington, D. C. 20036 Mr. James Rivello Dr. M. Stanley Livingstone Plant Manager 1005 Calle Largo Shoreham Nuclear Power Station Sante Fe, New Mexico 87501 P. O. Box 628 Wading River, New York 11792 i i ! i.
L ENCLOSURE 1
*/ o.= aseg),
- UNITED STATES
[,jit F; d!,. E! j NUCLEAR REGULATORY COMMISSION
"^5"*C' D C N 55
( \,[- / DEC1 1983 Mr. Clinton 5. Matthews, Vice President and General Manager Transamerica Delaval, Incorporated 550 85th Avenue P. O. Box 2161 Oakland, California 94621 Cear Mr. Matthews: The purpcse of this letter is to follow up on an agreement between Mr. Bixby and Mr. Denton that merters of their respective staffs meet, possibiy as early as the .eek of December 12, 1983, at our offices in Sethesda, Maryland, to discuss several technical issues regarding the Transamerica Delaval, Inc. (TDI) diesel generators which are installed at nuclear power plants in the United States. The meeting would be publicly noticed, and an NRC staff meeting .sunnary would be placed on the docket of all nuclear power plants using TDI diesel generators. The Enclosure to this letter consists of a list of cuestiens which we cre:ose to use as an agenda for the Teeting. If scfre of the c.es*icrs will recuire additicnal tir.e tc ar.swer, tr.en a later ritten res;ense weuld be acceptable. If preprietary infor nation must be discussed, the meeting may be clesed and the infer 1r.ation may be withheld from public
- disclosure, in accordance with the provisions of Section 2.790 of the Cc.rnission's regulations. Please contact Mr. R. Caruso (301) 492-8392, of my staff, to discuss the details of tne eeeting.
Sincerely, Thomas M. Novak, Assistant Director for Licensing Divisien of Licensing Office of Nuclear Reactor Regulation Encicsure: As stated cc w/ enciesure: See next page XA Copy Has Been sent to PDR
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C- a 1 7+. y a ww - / m
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j . : . - l l Enclosure . q- .. , 1. Describe the history and evolution of the crankshaft -
- design of DSR-48 diesel generators.
- 2. The original Shoreham crankpins were 11 inches in diameter, but the replacement crankshaft has 12 inch crankpins. Please discuss the reasons for the change in size, and the reasons for any cther changes in geccetry, metallurgy, or fabricaticn of the cranksnaft. '-
- 3. Other vendors who supply components or services to the nuclear power industry have formal methods of inforcing their custe-ers cf problems or procuct improvements. Please Describe TDI's program for such notification.
4 In its report on the crankshaft failure. LILCo's consultant ncted that the forcing function used by TDI in its torsional analysis changed significantly between 1975.and 1983. Describe the history and development of the forcing fuctions used by TDI in assessing the adequacy of its Y-16 and straight-8 engines. Please explain how the effects of changes in the forcing functions have been evaluated to' ensure that these changes can be accomodated by the various parts of the engines. *
- 5. Descrice ??!s efforts in uncerstanding the causes cf the Snorenam crankshaft failures. Include in your response any conclusions you have reached after considering the report by LILCo's consultant, and a description of any actions you have taken or plan to take as a result of these failures.
- 6. Design calculations for major pieces of equipment are usually independently checked and verified. Explai.. how this process was carried out for the original and replacement crankshafts. Irelude, if possib7e, examples of actual calculations or tests wnien were done to verify'the cesign.
- 7. LILCo has also identified problems with failures of the diesel engine cornecting rod bearings. We understand that they have provided you witn a copy of their initial reper: on the subject. Please describe the history of the design and manufacture of the ccnnecting rod bearings in TDI engines. Discuss how the bearing material specifications have developed, including any changes since the Shoreham engines were built and the bases for such changes. Also describe the processes by which TDI ensured that the caterial met the specifications.
If you have experienced any other bearing pecblems in other TDI engines, please discuss them. , 8. Discuss the history and evolution of the design of the pistons used in TDI engines. -
. , , ,-- , . --, vn--- - - - - . - - .,--n , - - - --m--. - - - ~ n..---- ,
..' '.- ITER 88m8nOs h Wee 7,, O . . ENCLOSURE 2 Delaval =a =~
P.O. Bou 2101 l Oakland Castfomia 94421 (415)577 7400 December 16, 1983 Mr. T. M. Novak Assistant Director for LientIng Division of Licensing Office of Nuclear Reactor Regtlation Nuclear Regulatory Commission Washington, DC 20555
Subject:
Standby Diesel Generators at Nuclear Power Plants '
Reference:
Mr. T. M. Novak's Letter of December 1,1983
Dear Mr. Novak:
The Users' Group gave us a copy of the three-page list of nine questions at the November 30, 1983 meeting. This is the same list sent to us on November 29, 1983 by your Mr. R. Caruso. We are today sending the Users' Group answers to the nine questions. Since the content of the nine questions is essentially the same as the list submitted by the referenced letter, we are sending you a copy of our answers to the nine questions asked by the Users' Group. We trust that these nine answers are responsive to the list submitted by the referenced letter. However, if there are any additional questions, please don't hesitate to call. We intend to cooperate fully with the NRC and the Users' Group to answer all your questions. Very tyuly yours,
,s
.djb,i2fik .
C. S. Mathews Vice President and General Manager CSM/WVD/pn XA_Copyjas Been Sent to PDR 31216 k Nem=eWoo. l
i . , I N#CEESTIDNS , , , Q #1 - Describe the history and evolution of crankshaft design of DSR-48 diesel generators. A #1 - The DSR-44 diesel engine crankshaft was developed from the DSA-38 engine which has been in production since the early fifties. The DSM-34 was developed from the "Q" engine which was in production since the thirtlos. The "Q" engine had a 18" diameter crankpin and , 11" diameter main Journal and was rated at 268,327 and 368 rpm. The j R-6 engine started with an 11" diameter crankpin and 11" diameter ; main Journal (11* x 11") and changed to 11" x 13* anc! 12" x 13" l during the course of evolution, from 300 rps originally to 327, 360, l 375, 400, 425 and 458 rpm. The first DSR-48 engine was built and shipped in 1969. It was rated for 440 ApM operation. The first 458 RPM DSR-48 er.gines were built in 1975. O sefa) - W at frompted t you <to khange- the - size -of the crankpin after the" -
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Shoreham engines were built? - A #2(a) - TDI changed the crankpin diameter to achieve higher torsional stiffness. This change to the engine was made to give broader capabilities as a driver for different applications, such as pump and marine drivers. Further, the change is a part of the evolutionary process. For example the crankpin of the "RV" had been changed from 12" to 13" the previous year for the same reasons and not because of a problem with the 12" pin shaft. Q #2(b) - men was the decision made to change the crankpin size 7 A #2(b) - The drawing for the it" crankpin crankshaft no. 83-310.-05-AD was dated 2/4/75. - Q e2(c) - Why was the crankpin fillet geometry changed? A #2(c) - The "RV" erankshafts have a 3/4" .fi11et. men the charite was made to the crankpin diameter of the "R" . engine TDI made the fillet radius change to again commonality in design het ween the R-44 and "RV". The commonality is desirable from a manufact e ing standpoint. t .
- Q #E(d) - leien was LILCQ informed of the change its v ankpin size?
A et(d) - Ismediately following the crankshaft fail are at LILCD.The requirement for a quick supply of new crankshafts dactated the 12" diameter pin shaft be supplied because it was the only shaft immediately available. G #3 - What is the TDI mechanism for informing its customers of probless of product improvements? Does TDI use a technical information letter approach or its equivalent? l l
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A #3 - The TDI sechanism for informing it's customers of problems or product .
. . .Leprovements is the Service Information Memo (SIM) program.
The SIM is to a Technical Information Letter with the additional advantage of an indes system, which allows the collected SIMs to fore a fourth volume of the Instruction Manuals. Additionally, TDI informs nuclear plant customers of " potential defects" as required by Federal Law is CFR 21. G #4 4 - In its report on the crankshaft failure, LILCO's consultant noted that 4 (a) the forcing function used by TDI in its torional analysis changed significantly between 1975 and 1983. A #4 & The torsional analysis for LILCD used the forcing functions which were 4(a) in the TDI computer progree data base in 1974. Ide made teso changes to the forcing functions values in 1975. The second change made in 1975 l 2
. mas used until 1977. In 1977, se made minor refinements to the forcing functions'and these' remain in ese today.~' '
Q e4(b) - Why did this change occur 7 i A #4 th) - The analytical results from the torsional analysis are verified by i torsiograph tests. Since the intention of the analysis is to accurately predict the natural frequencies and stress levels of the diesel genergtor system, input data to the computer program is _ adjusted, so that the calculations result in agreement eith the test results. The changes to the forcing functions are steps taken to estch calculated or predicted values with those obtained fece tests. Der current forcing functions predict slightly higher stress levels than seasured. O e4(c) - What effect does this chagne have on any other components of DSR-44 engires? A 44(c) - None. The changes to the forcing functions were made to get the computer assisted computation to accurately predict the actual l behavior of the engine generator shaft mass elastic system. Q e4(d) - What forcing functions were used in the design of other TDT engines
- (sucW as the DSRV-16-4s) in nuclear service?
A #4(d) - The following tabulation shows what forcing function groups were used for all the TDI engines for nuclear service. l O
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CONTRACT CONTRACT TORSIONAL HAfDO41C NUMBER NAME REPORT COEFFICIENT ,, DATE BRoup , 74018 LILCO 7/18/74 1 - 75841 S. C. L 6/27/75 1 75005 - MUDGENS 4/25/75 1 1 74846 CP8L 1975 2 74833 MP&L 9/15/75 3 75817 DLME-CATESA 3 1 75051 C. L I. 7/9/76 3 ) 75084 19P83 4/16/76 3 ' 75089 TVA-MLLEFGdTE 4/27/76 3 . 76801 7. L*. 8. I. 1/5/76 3 I 77901 CONSUMERS 4/26/77 3 - j 74839 GULF STATES 5/3/77 3 77 tit 4 TVA-STRIDE 8/16/77 4 , 76821 M DRSIA PWR. 8/1/74 4
'78886 MAANSMAN 6/22/78 - 4' 81015 S. M. U. D. 9/10/41 4 1
HAlWONIC C M FFICIENT BROLP 1 1974 TD 1975
. HARMGi!C COEFFICIENT BROLP 2 1975 MAfMONIC COEFFICIENT SROLP 3 1975 TO 1977 .
HARMONIC COEFFICIENT SROUP *4 1977 TO CURiedT HARNONIC CDEFFfCfENT LISTINB DERIOD 74 - 75 75 75 - 77 77 LISTING FROM lit m CD&L MP&L STRIM
; HOR *0NIC 680U0 1 8R0U0 2 GROUP 2 GROUP 4
.5 11.80 90.88 97.SS 155.45 i 1 29.62 89.78 94.34 94.21 l 1. 5 19.88 94.88 188.70 129.21 2 24.05 45.43 42.53 42.61
- 2. 5 at.at $2.38 65.61 71.51 3 19.97 14.84 15.57 IL5E i 3. 5 16.78 38.91 44,El 42. 7E 4 13.38 29.84 30.25 27.62
- 4. 5 9. SS 12.48 12.73 12.72 1
5 7.38 9.21 9.39 9.38
- 5. 5 5.65 7.91 7.14 7.14 6 4.18 5.55 5.68 5.68
- 6. 5 3.29 4.39 4.49 4.49 7 2.66 3.68 3.69 3.68
- 7. 5 L 23 2.98 3.85 3.84 4 1.87 2.44 2.52 2.52 1
.__ ,__. ___ _ . _ _ _ _ , _ . , _ . _ _ _ _ _ _ , _ _ _ . - _ , - _ , , _ . - _ , . _ , . . , . . . . , , _ _ _ ___,_,____,m_,,__ ,_,7~,-
. . I f
- 8. 5 1.51 2.28 2.26 2.26 9 1.42 1.92 1.97 1.97 -
- 9. 5 1.25 1. SS 1.53 1.52 -
10 1.11 1.25 1.27 1.27 18.5 1. SS 1.13 1.14 1.14 11 .91 1.81 1.82 1.81
- 11. 5 .82 .88 .89 .89 12 .74 .78 .79 .79 ..
O e4(el - Have these forcing functions changed? l A #4(e) - The current Tn values have been in use since 1977. j Q ea(f) - Please describe the development of the forcing functions for each TDI diesel in nuclear service. l
. A #4 (f) - The forcing functions are derived from Fourier analysis of the torque '
vs crank angle diagram for one cylinder. These forcing functions are l subsequently adjusted to correlate the analytical results with test results as already noted. , Since all the TDI engines for nuclear service are rated at 225 beep and 458 rpe, (except for S.C.E. ) which has a lower rated RV-28-4, the forcing functions are similar. 0 #5(a) - What does TDI view as the reason for the Swesham crankshaft failure? ~ , A e5(a) - Site operating stresses approximately equal to the enduram limit caused high cycle (18. 86 to 18. 87) fatigue failure of the crankshaft. G e5(b) - leist conclusions has TDI drawn from the LILCO failure report? , A e5(b) - The operating stresses in the 11 x 13 cranksaft were essentially equivalent to the endurance strength and results in high cycle (18 E 86 to 18 E 87) fatigue failure. The failure is effectively an-unfortunate endurance limit test. Even a small reduction in stress
! (perhaps only 2 or 3 ;-. 4) would have resulted in unlimited life.
Since the 12" x 13' crankshaft is subjected to significantly reduced stresses it will result unquestionably in a shaft that will give unlimited- Life. In these setterm we are in complete agreement with the LILCD/ Failure Analysis Associates report. However, we do not feel
. that the FaAR analytical analysis, particularly the finite element model (Sec. 6 of report) is necessarily satisfactory. It fails to predict the actual state of stress sensured by Stone & Webster (Sec. .
. 4) and it fails to satisfactorily prediet the crack location and I direction. The crankshaft stress analysis is inadequate and the n fore does nnt fully explain the reason for failure. TDI is currently engaged in its own .stressi analysis program, unich is expected to yield a sore accurate analytical model and a clear
understanding of the stresses which caused the failure. . Q #5(c) - Wat. actions has TDI taken o. does TDI plan to take foe Shoreham and other plants as a result of the Shoreham crankshaft failure? A #5(c) - TDI plans to continue its investigation into the reason (s) for the Shoreham crankshaft failure in accordance with the outline given in the discussion presented by Mr. Greg Beshouri (attached). The results .. of these investigations will be published at the appropriate time 'and - made available to all interested partles. O e5(d) - Does TDI plan to prepare a report of its own regarding the Shoreham crankshaft failure? A e5(d) - TDI will develop a formal report containing itM views on the reasons for the failures. Much of the report will be developed using understandings gained from the R&D studies outlined above. G #6(a) - Describe how TDI design calculations are reviewed and independently verified? l A e6(a) - Calculations performed by design engineers are reviewed, signed and dated by the Manager of Design Engineering. Designs which rely on calculations in which assumptions cannot be verified are subject to experimental testing by the Research and
. Development group. In some instances the Manager of Applied Mechanics will also review the result. Some components are subjected to testing on a shaker table, if practical.
O e6(b) - What detailed stress analysis of the crank web and pin were performed? A e6.(b) - No detailed analysis were done on the crankshaft other than the crankshaft was designed to American Bureau of Shipping Rules, as detailed in the attached excerpt from the rule book. TDI has successfully used such rules as a design standard for 45 years. The R-44 crankshaft was developed from the "Q* engine with it" x 11" (18" diameter crankpin and 11" diameter main Journal) to the first "R" engines with 11" x 11" erankshafts then 11* x 13" to the current ita x 13' configuration. G 67 - Could the problem with the crankshaft have been detected during initial torsiograph testing at the factory? A 87 - No. The total vibratory amplitude usasured was only + or .50 deg. which equates to a stress of $314 psi. The portion attributed to the fourth croer was + or .43 deg. or 4579 pai, well within the Sete poi allowed by DEMA for single order contribution. (The stress requ. ired to break the crankshaft was more on the order of + or - 38 to 35 ksi.) l l l _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ ~ _ - . _ - -- . . - _ - - - - _ _ . - - - . - - _ - - - -_ _J
Q #8(al (i) -LILCD has also identified problems with failures of the diesel engine connecting rod bearings. We understand that they have-provided - you with a copy of their initial report on the suojs:t. (a) leiat does TDI view as the reason for the Storehas bearings failure? A #8(a) - Four of the forty bearing shells were reported to be cracked, only one of which had a significant crack through the edge of the top - shell. The small piece 4-7/16* Iong and 11/16" wide at the thickest point was Jacked apart from the main body of the bearing shell for study. None of these shells had failed to the extent that the clearances were opened up nor did any of the shelle result in damage to the crankpin. A photo- sierograph of this broken bearing showed porosity ranging from S.81 to 9.83 in diameter. In addition, the- j saterial was found to be below standard for elongation. An i examination of the fracture surface with scanning electron microscopy identified some of these voids as the apparent crack initiation locations. In compression the porosity would not pose a problem. However, the overhung bearin~g arrangement resulting from a 1/4" chamfor on the connecting rod as shown in Figure 1.1 (attached) in conjunction with the normal yaming of the crankshaft, put the !.D. of l the bearing into tension. The surface porosity , acted as stress l intensifiers and with the poor material elongation characteristics, j initiated a crack. This was clearly a satorial rather than design i problem as evidenced by the fact that more than 300 cylinders of this connecting rod areangement are in operation, many of which have operated for more than 25,000 hours without bearing problems. Q #8(b) - What action has TDI taken to ensure that new bearing will not fail in 1 a similar fashion? , i A #8(b) - In regard to LILCD and other A-48 engines installed in emergency standby service, the crankshaft is fitted with a connecting rod which has a sma11 re 1/16*, chaefer on the edges. Figure 1.2 (attached) i shows the bearing is fully supported. Even though there may be some porosity in the bearing shell material, the shell is in compression
- and therefore minor porosity would not be detrimental.
Chemical and physical properites of casting lots or heats are tested to verify compliance with requirements. In addition, TDI does a visual inspection for porosity of each shell during manufacture. G #8(c) - What other TDI engines in nuclear service use similar bearing material? A #8(c) - All of the nuclear and cosuseecial engines which TDI sanufactures contain bearings using identical F438-T5 hearing material. This material is a 65 tin content aluminum alloy. We purchese castings from Aluminum Company of America and perform all machining and plating operations at the Oakland facility.. Q #8(d) - letat action has TDI taken for other engines to preclude their failure in a similar fashion? l -G-
I l A 48(d) - The bearings in all ' ether engites in nuclear service have connecting red and bearing arrangeoemts shown in Figurs 1.2 and 1.3 (attached). I"ach provides full support for the hearing shell. The hearing sheli is in compression, bots. from crush and operating forces, wit h no portion of the shell in tension. Therefore, if bearing material contains siner porosity, as all castings do, the loads present sill not a-t with the stress intensifiers and result in - cracks. Q 48(e) - What controls has TDI provided on bearing material in the past? A 08(e) - The purchase order for bearirg material has required the supplier to l furnish a Certified Material Test Report (CMTR). This inas a requirement in 1974 and still is. The CMTR is reviewed for compliance ; to the material requirements. All bearings are inspected visually for ,
, porosity during the manufacturing procass.
Q 88(f) - How did and does TDI ensure that bearing material asets its specifications? A #8 (f) - In 1975 TDI initisted it's osei bearing saterial sample testing l program to check checeical and physical properties against specification and the CMTA supplied by the vendor. This program remains TDI's standard practice. , G 484gl - What other experience has TDI had with connecting red bearing failures, of any kind, in any nuclear oc non-nuclear installations? , A #8(g) - TDI customers have encountered occasional babbitt fatigue. It has the appearance of small isors holes in the surface of the babbitt. In addition several users have suffered the results of faulty reinsta11ation, dirt ingestion and abuse which have resulted in ; bearing failure. Q #8(h) - What procedures does TDI use to ensure that bearings and , journals are properly designed and manufactured? A 48(h) - TDI has been designing , developing and building engines since before 1938. The intervening years have provided considerable experience and
, knowledge regarding enhat constitutes a properly designed crankshaft i
,lournal and mating bearing, such as L/D ratio, surface finish, battitt, thickness, etc. In addition, we esork closely with the bearing ,
materiat vendors regarding the bearing design. All of this information culmanates in a design that is translated into detail drasetngs for manufacturing. The IM department ensures conformance to
- the drawing requirements through TDI's 18CFR589 program. The hearing material vendor provides Certified Material Test Reports (CMTR's) for
! sach casting heat ediich are review for conformance to the dressing
! requirements and are verified by TD1's own Chemical 4 physical test for each casting heat. Q sS(i) - Describe any problems you or any of your customers have encountered , with the use or manufacture of aluminum bearings with beteitt
~ - - _ _ _ _ _ . - - _ _ _ _ . _ _ _ . _ . - _ _ _ _ _ _ _ . . _ . _ . _ . _ _ , , _ _ _
overlays. A #4(i) - Users have occasienally encountered babbit fatigue in the hearing overlay. This may occur if the tin content in the babbitt is too low, resulting in a weaker babbit. The composition of the babbitt is monitored quite closely. TDI has initiated a change in the babbitt composition to further improve the fatigue resistance. This calls for the inclusion of 2.75 - 35 copper in the S. A.L - 19 babbitt. With ,, the TDI hearing design,. babbitt fatigue or even complete babbit . overlay loss does not result in any sort of catastropnic baaring , failure that might cause the engins to stop functioning properly. TDI has also occasionally encountered porosity and los elongation characteristics in the aluminum castings used to manufacture the bearing shells. Q #9 - LILCO as also identified problems with cracks in almost all of the piston skirts at Shoreham. A #9 - This statement is incorrect. There has been only one piston at LILCD which has been identified as having a crack. The suasinations being conducted at the site are using an " eddy current" inspection process which TDI and it's Metallurgy Consultant considers not suitable for examination of cast nodular iron surfaces. This oddy current process i has predicted linear indications in the piston skirts which in most cases may be nothing more than the grain boundaries within the ! nodular iron structure. . Q #9(a) - Describe the stress analysis and testing that has Dean done by TDI in the development of type F, AN and IE pistons. . A 39(a) - AF, AN, and AE pistons have been subjected to many experimental test programs to reveal the patterns of stress and temperature existing in the assembly. The tests included studies of thermal distortion, ,
. effects of combustion pressure and inertia forces. Finite element analysis (FEM) was attempted on a crown, however the technique proved to be less than adequate.
piston assemblies of the AN and AE type were successfully run for 647 hours in the emperimental R5-V12 engine at 514 rpm aesi a power level of 937 BW per cylinder to support the results of the static and analytics,1 studies. Nuclear standby generator diesels are rated at - 458 rpm and 689 BW per cylinder. Therefore the test work subjected the pistons to considerably higher , operating stresses than the pistons used in any standby engine.
- 4 Q 99(b) - Has TDI or any of its customers encountered sietlar or different probless with piston c*acking?
A #9(b) - The crack reported by L is the first such crack identified and reported on the modifi "AF" style piston skirt whien has been manufactured in accordance with design requirements. There are 252 ! 'AF" piston sAirts operating,- whien have accumulated in modified excess of 1,772,000 hours of successful operation. l
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l The "AN" style piston has experienced several field failures, ashich - have been attributed to high residual stresses not removed by a stress ralief process. There have been no reported failures of the "AM" style piston ashich have been stress relieved and properly machined. There are 1374 "AN" style pistons opeataing eshich have accumulated in excess of 2,768,000 hours of successful operation. The "AE" style piston ~1s the latest TDI R-4 piston design and incorporates prior 4-4 design and operating experience and now design knowledge ese have gained through our 4-5 engine test program. The
. "fE" piston design has been successfully tested in our R-5 test engine at 514 rpe and 302 BPEp and has acquired in excess of 7000 operating hours in a 16 cylinder 7000 kw engine in the field.
Q #9(c) - Has TDI modified its piston skirt design to improve stress levels in the area of the bolt holes? A #9(c) - As part of a continuing program of product performance and reliability improvements, TDI has modified tne piston skirt design to improve stress distribution in the area of the fastener holes and in the circumferential aid rib blend to the wrist pin boss. Q #9(d) - How and when were these modifications made? a A #9(d) - primarily as a. resul't of the studies' referred to in.the anesser to questien 9s, TDI concluded that a more massive boss around the bolthole esould better diffuse forces to the piston pin area. Calculations also verified that the protection afforded the fasteners against cyclic loading could be achieved with only 13 believille washers insteed of the original 26 esashers. On August it, 1982, piston skirt Sit-341-44-AE esas released for
.m oduction. It required that a change be made to the corebox in which e le sold for the piston skirt interior is formed. This change provided the secre massive bosses around the boltholes and precluded the manufacture of earlier designs.
l I l i l l
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CR4.KS-ATT ??#E55 QNALYSIS D40G4Am. .. . Greg Beshouri, Researen Engineer ItC.EEEfsIl05 Wtth tne failure of the 11" x 13" cranksnafts in tne LL.CD DSR-48 (S/N 74410/12) engine, TDI inatiated a stress analysis program (includtng physical '~ testing and analytical socelang) witn the oogective of determining tne stresses anc their sources in.an 8 throw 11" x 13" ..-ankshaft in orcer to tdentify the ac:ual causes of tne fatlure of tne LILCD snafts. In medition, this program is intancec to provice a more sopatsticated input for future crankshaft stress ar.alysts anc cesign. 53In.23E Litecat ure Review Grior to tne initiation of pnysical testing, an extensive review of tne avsalable literature was concuct oc. From this review we ceterminec, as re:e: ec, tnat a cranxs. aft in service is susjected to a comolex, cynamic state - of cocLine: stresses. Tne key to successful st analysis is an understand 1ng of sne source of each stress component and not ..:ase incividual cosoonents acd
.nte the comoined stress state. The literature indicated the necessity of strain ksge testan;. Tne technical panees also were a good source of id"crt:at t er. on what other researchers had- used in regard to gage type, length
- a4 2 : a-ion.
er.can! 09vsic ! Tegg, As not ed, tne literature revtew confirmed sne need for strain gage t ect tr;. At the :eginning of our investigation, Stone and Weester (LILCO censul tant s,) nac alreacy coe.mitted tnesselves to concucting dynamic strain gage t es*. t r ;, a math felt to be ver/ difficult to follow because of tne myrtad of t r.:t r n e?.t &t i on :rcDieus associatec with frecuency modulated (FM) telemetry (a ut* cc cf t rar.2: itt ing strain information via racto waves fro:s the operating c: exsnaft). T.wrefore, we electeo to perform statte strain gage test ng on an av.t'abiu enp r.a at our f ac t
- ity in the home it would complement the S&W
- .yr.eni: t c:t ing. Tais statte testing was des t gr.ec to prov2ce information nc:essery to interpect ar.d vertfy the feasiDility of the cynaste test data.
The test ng was done on a TDI Researen and Development engine with av 11" x
'2" crankshaft. The crankshaft is similar to but not icentical to tne 11" x 13" shaft eten failed at LILC3. The erannsnaft of tnis unit was statteelly loaoed to st:culate cynamic forces in the 5th through 8th tnrow of an R-48 engine rated at II: ::i 27.EP at 454 RPr..
7.e cr annsnaf t loads from gas :ressure (less inertia), torcue transmissacn an: torsional vibration were first samulatec incepencently. They were then r.r.:e.: in severs; cifferent com:2 nation to cetermine tne resulting stress. From
. .t s cata a ger.eral solution was ostainec oy wntch it as possible to orectet -
1;u:imw; Oran4snsft stresc for any commanation of sending and torstonal t.t r e::ss. v -,--- -m-, . - , --w--m- - , - c, .%.. _ _ _ _ _ . - , .
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The crankshaft was suojectec to torous in suen a manner as to vamulate l tirsicnal stresses from transalitted torque and from torsional vibration, and to bercing forces simulating gas pressure (less inertia). I The necessary torque was generated by fitting cylinders No. 246 . clearance volumes witn spacers and 0-ring seals (see Figures 1 & 2), and tnen l srecturing them with oil with tne two pistons located at 240 deg. and 129 deg. i A DO respectively. Simil,1rily, bending force was generatea by sealing and pressurizing cy incar No. 3 with the picten at *DC and 10 cegrees and 29 ATDC.
$1 List Pet 22"emenig Tne stresses generated by torque and bending forces were measuree by
, racistance type , strain tages located on tne No. 3 crankoin fillet and on tne ersnxpan (see Figures 3 & 4). Rosettes 9 tneougn E located in tne fillets 4
- .:aacured reaxircum strains anc their principle cirection. Rosettes A & F measurec
%rsacn and hencin; on tne surface of tne free part of tne pan. Comoarison of A L F (free- part of the pin) with B tnrough E (fillet), yielos tne stress car.:entastion effect of the cranxpin-fille $-web configurations.
t losette H (only outer' two gages used) located on the cylindrical surface of the No. 5 main journal verifiec tne actual torque inducac in tne system. A*;
. rosettet were rectangular three gage tyoe of 0.125" (3 mm) effective cngth, manufactured by Micro-Measurements (p/N CEA-46-125UR-129).
33.i.ittuence . pure torsion was first simuittec by pressuring cylinders 2 4 6 only in 349
=ci increeents from 0 to 1200 psi yielcing torques up to 2,368,099 in.lbf.
Dure :er:cang at T00 was t3en sir.ulatec ey pressuring cylinder No. 3 enly, ir. 40? ;si increraents from e to 1600 psi, representing a maximum peak firing s-es ure in excess of !?Q pst, (Note tnat tne primary and seconcary inertia , I forces of the piston anc connecting roc assemoly oppose tne firing pressures at:c 3 ave tNe ocu1 valent effect of lowering tne firing pressures by 377 osi wnen c eating at 450 rpm. Then, my crossuring cylinders 2, 3 and 6 amoroortately, comoinec torsion , ar.c sancar.g representing the actual stress state was simulateo. l
9e sure ten =1ng anc comoinee oewing ano torsion tests were receatec witn
- ylin:tr Ac. 3 piston located at le and 29 equivalent degrees ATDC.
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The s:cain gage cara were recucec to maximum and minimum princiale l ctretcac anc ranciple directions.
s From Dencing loab and torque cata, general eatnematical expressions were - cerivec for nominal stresses in the free part of tne pan due to bencing loads and torque. In addition, stress concentration factors were calculatec for , various fillet locations. I From tne combined strees data, a general analytical technique (using
*' c 9 e ' s circle) for calculating combined stress cue to a given bending load and .. i tc.rque was generated. It was tnen confirmed tnat tnis tecnnicus could be
{ ac;:11ed in t-everse, i.e., given a certain combined stress state, the tending i 1cai and torque creating this stress could be calculated. Using this technique the dynamic stress data taken by Stone & Wooster on
'Jnit *01, TD1 S/N 74611, at LI:.C0 were tnen broken cown into comoonents of cynac. c sending load anc cynamic toroue creating tne stress, resulting in a clear uncerstanding of tne dynamic state of stress components. had the static testing not been concucted, at woulc not have been possaale to satisfactorily Cec 13ner tne dynaenac stress data taken by S&W.
M Q G o %G8p* cecause of the failure of tne LILCO cranksnafts and a recuirement to
' clear'y uncerstand the reasons for tne failure and given the success to date of tne seve-a; wthocs of crannsnaft stress analysis amplied to tne 11" x 13' shaft, we have committen ourselves to an on-going crankshaft stress analysis w .;ry an.
Tnis program will proceec in two coeslimentary directions, analytical and e.cerizantal Fig. 5). First, static tests will se conducteo on all crannsnaft configurations to cetermine stress concentration factors in torsion anc bending. Concurrently, a cyname mocal nnten precacts torque and oencing loac will ne generatec. The s rass concentration factors and dynamic bending loac and torque calculations will snen :,rovice inout for ' a second mocol wnien wall calculate eranxshaft etress vs craneangle. Tnts calculation will then De verified by cynan:1c strain
.:.g e tests on se;ectes erannsnaft configurations. Once tne stress calculation procacure is verifiec, exact maximur.: stress and exact operating factors of ssfe:y for any crannsnaft configuration can ce calculated.
*n accitten to provicing cosign information for new engine programs, the calculation procecure w111 De used to confirm and refine tne less to::51st icat ec, more conservative stress calculation procecures currently useo on 4-4 series engines in nuclear service.
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7: n g [ *)g g UNITED STATES NUCLEAR REGULATORY COMMISSION 3 - ' L f WASHINGTON, D. C. 20555 l
%, j[ . January 27, 1984 Docket Nos.: 50-416 50-312 MEMORANDUM FOR: Chairman Palladino Commissioner Gilinsky Commissioner Roberts Commissioner Asselstine Commissioner Bernthal FROM: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
BOARD NOT:FICATION 84-018: FAILURE EXPERIENCE OF TRANSAMERICA DELAVAL EMERGENCY DIESEL GENERATORS IN MARINE SERVICE In accordance with the procedures for Board Notifications, the following information is being provided dir' ectly to the Commission. The acoropriatr. boards and parties, for all facilities with TDI diesel generators, are beine informed by a copy of this memorandum. This information, which sup,,lemente that provided in Board Natificatters 83-160 and 83-160a, is relevant to all facilities that have diesel generators nanufactured by TDI, including Rancho e Seco, which is before the Commission, and Grand Gulf (an uncontested case), which is scheduled to come before the Commission for' full power authorization in the near future. Before the crankshaft failure cccured at the Shoreham huclear Powar Station in August 1983 bearings regarding the adequacy of the Shorehan diesels had been scheduled by the Shorehan Licensing -Board. Those hearinos were subsequently postponed, pending the completion of the cranksheft failure investigaticr. However, before the hearings were delayed, a sbbstantiel amount of discovery took place between Suffcl's County (the princino? intervenor at Shorehan, the County.) and the Lenri Island Lightino Coerany (LILCo). On request of the Ccunty, the Board issued suhpcenas tr. the Stato o' Alaska, U. S. Steel. and Titan Navicatior., requesting that they crovide copies of all information in their possession relatino to failures of the TP' diesel engines they had in marine service. l l _ : u.: .;_ 1
i
.Th4s information was supplied to tiie Ccunty ~in September and ' October 19P.3.
In late December,-in response to a request from the NRC Shoreham Project - Manacer, the County provided copies of the raterial to LILCo and tc the staff (Enclosure). This naterial is being provided to the Boards because the staff understands that the-engines discussed in- this material are very sira11ar to other craines supplied by TDI for use-in nuclear power plants. Because of the commonality of many components amono the different models of.ercines narufactured by TDI, the information is potentially applictble to all TCI. enoires in nuclear service. The staff will review this naterial and weich its significance as part of the overall assessment of the reliability of TDI. diesel engines.
\
(\ ((LOftl 3 t :h' t ( u DarrellG.-E!senhut,Oirector Division of Licensing. Office of Nuclear Reactor Regulation
Enclosure:
- 1. ' Letter _ fron A. R. Dynner (Suffolk Ccunty) to A. F. Eerley (LILCc) dated 12/21/83 cc: See next page J
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i WAmnixoTow, D. C 2o000 TELEPEONE (SOS) 488.FOOO IN FITTWnUnos CABLE: NIFERI IIMTRIG.1"'M.J0 Wee 05 & ECTERSO.1 TELEX espeOS NTFW UI 8800 MKTER 3CIIJPINO December 21, 1983 """***""""d"""* 202/452-7044 Anthony E'. Earley, Jr., Esq. Hunton & Williams P.O. Box 1535 707 East Main Street , Richmond, Virginia 23212
Dear Tony:
In accordance with our telephone conversation last week and pursuant to your request of December 8, I am enclosing herewith all of the documents which the County obtained by virtue of its subpoena to U.S. Steel Corporation and to Titan Navigation, Inc. Under cover of this letter, I am sending copies of the enclosures directly to Ralph Caruso of the NRC Staff. Sincerely yours, Alan Roy Dynner ARD/dk Enclosures cc: Ralph Caruso
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l D22.3C37332."JT O}' .7UCTLUC WE3GS , cms:c.t er m:::t invsrc.71.snc., l February 2,1977 i fir..DouglasH. Martini , General Manager Dela' val Engine and Compressor Division P.O. Box 2161 Caklar.d, California 94621 J
Dear Mr. Martini:
Inspection of the reworked cylinder heads. received on board Fi/V CDLUMBIA indicate that snme type of seal has been ' installed.on the top of the valve guides, a slinger placed on the valve stems,land a sealunt applied to the keeper assembly. Informal information also indicates that some-or all of the valve guides were sealed in some manner to the heads.
- It is. requested that a repo 't and details of the modifications be furnished as soon as practicable.
The rocker arm a.semblies were also inspected tipon' return from your facil i ty. Weld splatter was noted attached i.ns-ide of some rocker
-push-rod sockets and on other components;. Additionally, indications of welding electrodes being drawn across the fin,ished ends of several rocker arms, bushings, and pins was evident'. This condition wa's pointed out to Mr Trussell, requires on si.te correctiye action, and is disturbing to the State.
Ouring our meeting in Seattle on Ja' n uary.13,1977, 'th'e firinq ring problem was briefly discussed, but no r'esolution or planned action was kncwn to have been reached. Under secarate ccver, I am miling you representative rings that had been utilized with the removed cylinder heads. The continous problem, wherein we' experience firing ring burn / blow out at the 3 and 9 o' clock positions, is evident.
, The only conclusion that I can reach is the fact that the existing cylinder heads cannot be evenly pulled down'due to unequal head bolt locations. Pendin'g any other instructions, bea' dvised that the re-worked cylinder heads are being reinstalled using the same type firing rings, Very tripurs, i
/hhE1%:..a Harry Case ttarine Superintendent cc: Donald Harris, Con 7nissioner
!!illiam Hudson, Director Administration Office Donald Davidson, Attorney .
Lockheed Shipbuilding (Attn: Elwin Messei-) ilugh !!c00nald, Port Engineer liax 7binden, Special Project Engineer /
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m.t wenona, sonno.t _ f 02N.MTD3ENT O.7 E)tC2E 7/O"riS cmseser.umtrmsn wres Januar.v 25. 1977
!!r. Douglas H. flartini General l*anager Oclaval Engine and Compressor Divisinn P.O. Box 2161 Oakland, California 94621
Dear fir. Martini:
The inspec'. ion of it/V COLUMBIA main engines, as indicated in item 4 of ycur telex of January 14, 1977, was completed on January 19, 1977. A reetinn was held that date aboard it/V COLUMBIA with your Mr. Trussell and .*tr. 'larich in attendence along with out fir. Zbinden, Ffr. Reselin, I*r. Rulin and myself. A, partial summar ant! reen:: ended ' action as agreed to 6y.y tha of.the State inspection results is,as follows:
- 1. A total of 37 (thirty-seven) cylinder heads will be removed from the vessel .with crew assistance, for shipment to the factory for rework and return by Delaval. Rework may triclude critting back and counterboring the valve guides. Work would pass.ibly alsn be done in connection with valve stem sealingS, sea.1 keepers,'. installation -
of umbrella shieNs, etc. Additionally, exhaust. valves would be inspected, s. eat dye-checked, valves and seats skinined as deemed necessary and heads hydro tested. It was also agreed to return the rocker assemblies to permit factory ~ replacement of the oil passage lead plugs with steel plugs. It was further agreed that the rocker box bolts had not been a problem since they were changed out.
- 2. Liners and seals looked generally satisfactory. !ir. Trussel.1 pointed out that the ljner shoulder gasket.crushishould be chec!:cd This has not been done by the State in the past, basically because - -
no data or requirement therefore is known to exist in our engine ranuals. fir. Trussell advised that this will be. checked nrior to ref .stallation of the cylinder heads and at that time we presumSblo will obtain the necessary data and criteria. '
- 3. The borescope inspection reveah.J that the bolts in the piston !
ar.d the locks were satisfactory, except that 1 (one) .niston had the incorrect' type of locks. This latter piston orig.inally was to be returned to the factory for reclating, but had to be re-installed for emergency use when an existing piston becanie danaged by a stuck valve in a new head assembly. Liner cross-hatching and pistnn rings looked satisfactory 'as far as the
Mr. ' Douglas H. Martini January 25,1Q77 General bianager Page 2
~~
'inspec' tion could determine. A problem with piston rin'q groove !
ridges was brought up by the State. Ring clearance is satisfactory ' and no one had any idea as to its cause. 'Delaval personne1' indicated
- thet no problem therein was anticipa ted.
- 4. Timing was checked con the port engine and found satisfactory although slightly late. The starboard engine was not checked.
Delaval personnel will verify Top Center. later.
- 5. It was agreed that the exhaust manifold leakage problem persists.
No ideas that would improve the situation are apparently immediately - available. Additional engineering design development in this area appears necessary .fo/ proper' and final resolution;. S. .The Stata agreed to _ delay departure of the vessel from the repair facility until February 11,1977 to permit sufficient time for cylinder head rewor'< and reinstallation. This will defer the testing of the instrumented turbocharger by one week. However, the-general consensus was that the data gained would.not result in any innediate turbo fix. We could be lookin@ at several months in this respect and is presumably why you are consigning four turbos for emergency service.
- 7. No changes in cams and fuel pumps are presently contemolated.
- 8. Engine crankshaft dettection was '
reportedly had .0034" origin'a1 and is, discussednow .007".wherein Some confusion an engine exists with us in this' regard. Mr. Trusself ir.dtcated he would , chec% the records and advise us in this matter.
- 9. Mr. Trussell pointed 'out that header to nozzle fuel line interference with the indicator cocks was. apparently.c.aused by the lines.being imprcperly furnished. Presumably-some action will be forthcoming infthis regard. .
- 10. Meters and fittings to permit accounting of Tube oil addea to the engines should be aboard the middle of this week.
The results of the meetings held at Pier 48 on January 13, 1977 and again on board M/V. COLUMBIA on January 19, 1977 are encouraging. It appears .that the existing engine deficiencies and their impact on our overall transportation system are fully recognized. The time frama for corrective action presently underway hnd/or planned remains critical and requires complete resolution at the earliest. . Very truly yours, Harry Case Marine Superintendent HC:dsw cc: Conald Hfrris, Commissioner
-William Hudson, Director Administration Office Max Zhinden, Special Project Engineer Donald Davidson, Attorney Lockheed Shipbuildina (Attn: Elwin Messer) b w a
m -- 1/I4/77 J4 ATTN: MR U R HUDSON
\
t 1 C0r ::?. H CASE, VIA TELEX ,j I?E C0!! FIRM AS FOLLOUS THEAROGRAM FOR -THIS FOLLOUING IIEEK j
.CD OUn AGREEMENTS REACHED IM OUR MEETING YESTERDAY.
1 JCH:I BARICH, TRU3 SELL A!!D Tt10 SERVICCMEN UILL BE ON 90ARD THE COLtE3IA MONDAY, JANUARY 17, BEFORE N00N, PROVIDED FOG
?SR:!ITS. -
2 DE LAVAL 111LL !!AME ARRANGEMENTS TO CONSIGN FOUR TUR3OS FOR EMERGENCY SERVICE IN THE IM"EDIATE FUTURE. 3 NETERS UILL BE INSTALLED UNDER MR. SARICH'S DIRECTION TO OIASURE LU3E OIL CONSUMPTION. 4:. THE I!ITIAL VISIT OF.SARICH, TRUSSELL AND SERVICE!!E.J t/ILL SE TO SURVEY 30TH, ENGINE 5 'AND ALL EQU.IPMENT UTILIZING UORESCOPE.
..5 AFTER SAID ItJSPECTION, IT IS EXPECTED THAT MESSRS CAdd AND EE3LIN tJILL CORM UITH CUR PERSONNEL TO ARRA33E A JOINT
- PROGRAM UHICH VILL BE IMPLEMENTED SO THAT THE,F.ERRY CAfJ MAVE INITIAb SEA TRIAL APPROXINATELY FEBRUARY l 5 THE IllITI AL T*10 TR'IP3 0F THE FERRY t/ILL HAVE DE' LAVAL ;
SERVICE:tE:3 A30ARD TO ASSIST MR. 3ESLIN IN THE OPERATION. 7 "R. TRUSSELL UILL HAVE THE f!ECE33ARY COPIES OF THE PER-FORMANCE AtJD EXPLA:!ATIO*J OF UHAT THE UNITS SHOULD DO A3 A
!!RITEU? AS REQUESTED.
- 7. 5T REGARD 3, D. H. '! ART I:11 l
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- f Donald Harris Ceraissioner C:, trt. ant of Public Works em , January 17, 1977
-\\
non- W. R. Hudsm T susncn Delaval - Enterprise Status Director \ Division of flarine Transportation In direct response to my letter to !!r. D. H. Martini dated December 14, 1975, wa held a meeting at pier 48 of signal importance. Specifically, the meeting was arranged to determine exactly what actions nera to be taken by Dalaval prior to our resumption of schedule March 4, 1977, to ccrrect all known deficiencies and assure M/V COLUMBIA's main ensinas cperate at specifled performance. In attnndance were: For the Division - liessrs Hudson, Case, Zbinden, Mcdonald and Beselin. For Delaval - !!assrs !!artini, Trussell and one other representative. For Lockheed - M. . Elwin Messer and Attorney Bo'..r:an. The at' ached telex frem Mr. Martini is an outline of actions to be taken Calaval does acknowledge improper performance and has assured us they will pursue all areas until these main engines deliver as speqified.
!!r. I-!artini stated that he would stay abreast of this program personally.
Since we have .a history of failures, excessive lube oil consumotion and no re?1 explanation of why such failures have occurred, I felt it very necessary to draw the issue to a head. I have direct d Harry Case to brief our Attorney on this last meeting and Calaval's program as outlined. Ua are and will continue to hold all bills for parts and materials relating to correction of deficiencies. Although the actual solution may be a long way off, if at all possible; we are pushing Dalaval and through them - Lockheed for a total fix and I balleve documanting a reasonable case if future replacement becomes nece.Jary. I v:11 keep you adyised on a timely basis. Attachment cc: Harry Case A t4'Jtorney Davidson ax Zbinden Administrative Officer
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3 ) DSPARTMSNT O!F INJD:1210 WOUZIS C".=I C1l2.t!:::! rL:1!?:.inC.1 r?)C:1 R-N.1b*:1 !!111 (i! LEX UilD December 14, 1976 i*r. Douglas H. fiartini General tianager Delaval Engine and Ccmpressor Division P. O. Box 2161 Oa.iland, California 94621
Dear !!r. lfartini:
In our meeting of August 4,1976, my staff and I came away with the clear understanding that you recognized the Alaska flarine Highway's total unaccept-ability of the poor performance experienced to date with the Delaval/ Enterprise main propulsion engines installed in the ll/V COLUtiGIA. In that meeting we revealed only the surface;of a scenario of unparalleled malfunctions, repetitious repairs, staggering costs and lost revenue, not to mention a breach of faith with our traveling popuTace. The last sentence in your letter of August 11, 1976, expressed an intent to find constructive solutions to our problems. It is now four and one half ' (4 1/2) months later,kre have extended every profession 51 courtesy, met with various members of your staff on numerous occasions and made our vessel available to your firm both on the run and at dock side. Frca all indications you appear to have no solutions in sight! You are aware of course, that the il/V COLUr10IA is a vital link in our overall transportation system. Her performance oveq these past two and one half (21/2) years has been shameful and harmful to the integrity to meet scheduled operations by this State. Our records indicate that to date each engine has req 0 ired two major.over-hauls with less than 12,000 engine hours of operation. The records further reveal that to date the following has occurred.
- 1. CYLIt! DER LI?!ERS: All 32 c linder liners have been removed and reinstalled at least once for rep.lacement of liner seals.
b Mr. Douglas H. Martini Decembsr 14,197G
- 2. chi:CER HEADS: All 32 cylinder heads ,have been removed, reinstalled or renewed at least three times for reasons of leaking or fractured heads, under sized pistons, cracked valve seats, faulty liner seals, broken or stuck valves, broken valve guides, etc. Records further show that the State has expended $12,282.00 to repair fractured cylinder heads, has procured five new cylinder heads
, and consumed the two. shipboard spare cylinder heads in attempts to keep the vessel operational.
- 3. ' PISTOLS: All 32 pistons have been removed and reinstalled at least once for reasons of cylinder liner seal renewal, one renewed
. due to improper ring groove machining and one renewed for undersized diameter.
- 4. - TURBOCPARGERS: These units have been removed, repaired and rein-
, stalled or renewed a total of 16 times for reasons including ! leaking oil seals, vibration, abnormal noise, accumulation of foreign matter, rotor damage and a defective bearing seal housing.
- 5. EXPAUST MAtlIFOLOS: These assemblies have been removed and rein-
! stalled on several occasions for re.asons of heavy leakage of ! exhaust gas and soot into the machinery space, caused by frozen i expansion joints ~ and resulting cylinder head flange face damage. l Removals include shipment of the manifold assemblies to Oakland, California for redesign and modification. In connection with the exhaust manifolds, it is noted that 'the manifold water blanket / heat shield assemblies has been modified approximately, three times. ! 6. LUBRICATIO?! SYSTEM: Records indicate that lubH' cation oil consump- , tion is well heyond reason and is ' indicative of a major problem 4 as is the extremely short lube oil filter life:
- These above co rents pertain to only a portion of the engine problems i
e::perienced to date. i
- Other items such as cracked rod bolts, repeated glazing of cylinder liner l walls and the recent failure of a piston stud spherical shaped washer has l also occurred.
I Corrective action thus far on these items has primarily been limited to { repair or replacement in kind of the damaged or malfunctioning part of the l assembly. Except for the replacement of the leaking liner seals with a new i type scal, replacement of two defective pistons, replacement of the t6rbo- , char 9ar with the defective bearing seal housing and replacement of defective ! connecting rod bolts with that of a new design, the basic cause or reason i for the remaining problems are yet unresolved or uncorrected. i I
1 Mr. Douglas H. Martini D:cemb:r 14, 1976 l' !*e cannot continue to operate the II/V COLUMBIA as in the past, experiencing j r.::3t:d engine failures and/or malfunctions. Two years of ongoing field erg h ering experim:nts have not solved the problems. What is needed is a i sced hard ico% at the situation,.its cause and necessary permanent corr- 1 cctive action. This cust be accomplished rapidly and is the responsibility of tha engine manufacturer and his suppliers. i' Since the M/V COLUMBIA is scheduled to resume operations on or about March 5,1977, we shall expect your proposal and pe'rtinent time frame for corrective l action of all known deficiencies 'immediately after receipt of this letter. -
; Our only other alternative is to prepare the ground work for complete i
re . oval of the Delaval/ Enterprise main propulsion diesel engines and to preceed with reengineering of the M/V COLUMBIA. This is a course of action neither of us wants to see, but we cannot continue to function as a test beard for your firm. i t .I haya every intention to operate these main engines at zero to full rated i RPM's and will expect reliability, ecomomical performance and an elimination cf. this excessive engineering labor. i
- By copy heroof, I am apprising the Lockheed Shipbuilding and Construction a
Ccepany of these documented problems with a request for any corrective solutions they might have to these problems. i Sincerely,
! W. / R.p s eu s -
Hudson - l Director cc: Lockheed Shipbuilding (Attn, Elwin Messer) i Attorney Davidson j' Donald Harris i Harry Case
! Max Zbinden i
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. LAW OFFICc3 OF Fergusoni burdell E"."S*U' . "nu. 73 .roo acoses navio .u e.- ewto.~o *oMo*!'."..t" ' , EI "?o'2""EEbo - Seonle L liington osm - ' *~ o .r res ISUT.CW47 d . .mce. en 4tn *"M 32*C2~
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S I'/.1*T.'7/.'A.. "!;% ht"."o'.0 January 26, 1978 I Mr. Max Zbinden Alaska Marine Highways Pier 48 Seattle, Washington 98104 Re: State of Alaska v. Lockheed
Dear Max:
I have recently returned from an out-of-town trip and have heard nothing further from Lockheed. It would seem in order to commence working out the terms of the settlement. I would propose sending the enclosed
! letter to Mr. Bowman if it meets with your approval.
I would appreciate some assistance in determining precisely what should be written into an agreement'with Delaval and Waukesha, i.e., what specific obligations would those two vendors assume directly to the State. I am also enclosing a rough draft of the items and order in which this matter can be concluded except, , of course, for the propeller blade problem. In the light of the tentative settlement, I would think it entirely appropriate to commence negotiations for a propeller blade study, keeping in mind the fact that the tentative settle-ment will require cash payment to Lockheed of $161,751.96. i Very truly yours, FERGUSON BURDELL ,
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I. By: Donald McL. Davidson DMD:nl l CC: Commissioner Harris Mr. Dickerson Regan l I T
4 i Rough . Draf t Mr. David Bowman Lockheed Shipbuilding & Construction Co. 2929 Sixteenth Avenue S.W. Seattle, Washington 98134
Dear Dave:
I have just returned from ten days out of town. , It would seem to me the first order of business would be to put together the assignments of warranties on Lockheed's purchase order or contracts with Delaval and Waukesha, ! whatever they may be. There should be some Lockheed written documents spelling out current obligations. My thought would j - 1 be that as the initial step there would be an assignment by Lockheed to the State of Lockheed's rights against those two vendors and an acceptance of that assigment by the State, ! consent to the assigment by the vendor and an assumption by i the vendor of Lockheed's warranty obligations for those warranty items to the State. The State would then be dealing directly l with the vendors for the additional items the vendors will be
- , , , -c.m.
directly undertaking with the Stato. Very truly.yours, FERGUSON & BURDELL By: Donald McL. Davidson
- v. DMD:nl CC: Commissioner Harris Mr. Max Zbinden
; Mr. Dickerson Regan 4
I j i i l i 7 l i f l 1 l I
Rough Drcft AGENDA FOR FORMALIZA'I';ON OF LOCKHEED - STATE OF ALASKA CONTRACT l The following steps should, I believe, be undertaken. I l 1. Engine Work
- a. Lockheed should assign to the State and the State should accept the assignment from Lockheed of warranty rights agalnst Delaval Enterprises and Delaval Enterprises should assume all of the warranty obligations of Lockheed to the State under the main contract.
- b. Delaval should release the State from any claims on outstanding invoices covering engine repairs, i.e. , - those totaling $162,8 53.63, and
,ndertake u continued replacement of any originally supplied diesel engine heads which shall crack within a period of one year, continue current efforts to resolve turbo charger problems and satisfy head gaskets together with a warranty for any parts in the normal Delaval warranty form.
- 2. Emergency Cenerator i
Lockheed assigns its contractual rights and purchase order warranty rights against Waukesha to the State. l . - . .
I Tha Stnta munt th n mak3 its own arrEngnments with Waukesha.
- 3. The State and Lockheed will.then execute the change order which will be a deduct change order.
(a) It would recite that the contract balance including retentions and all other change orders is $401,751.96. (b) It would then recite that in exchange for a substitution of direct warranty obligations of Delaval and Waukesha and in settlement of all claims of the State of Alaska for defective work excepting claims arising out of or related to the propeller blades study and their replacement, that the contract balance should be reduced by l S200,000.00. (c) The change order would next provide that the ,. State will retain $40,000.00 of the contract balance i and pay over to Lockheed $161,751.96, reserving to ( - ! the State, however, the right to recover from Lockheed all sums expended in connection with a engineering j study of the existing propeller blades and appropriate l l l l t 4
, . . - . , , . , , - e _ _ c, m,_ .v--
bltdos tnd the ccet of rcplccoment of bicd s if required, the total obligation, however, shall not exceed 5210,000.00, including $40,000.00 presently retained by the State. (d) Lockheed would reserve its rights to recover - the S40,000.00 retained by the State. (e) The' surety executes and adopts this change order and shall be obligated for the performance and payment thereof by Lockheed. 8
law CFreCC3 CF Fergusou e ISurdell
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n2iln%. 21'."Ja'I!fei May 19, 1978 Commissioner Donald Harris State of Alaska Pouch'K - State Capitol Juneau, Alaska 99811 Re:- State of Alaska - Lockheed
Dear Commissioner Harris:
I met with Mr. Bowman of Lockheed today and made several minor revisions in the proposed agreement. In two placed we inserted the words "1978" season instead of "next"
- season in paragraph 3 (a) and paragraph 3(b).- It is my under-standing this is a clarification and will not_ change.the period of use which will extend from the' time of regular summer sailings through-the time of layup which may vary from the fall and perhaps into.early 1979.
.I also inserted March 31, 1979 as the specific date up to which Lockheed agreed to replace cracked heads. The specific date substitutes for the phrase "one year of the date of this agreement" but is actually the period of time discussed and negotiated.
I have also revised the last portion of paragraph 3C relating to fire rings simply providing in it that the State and'Lockheed and Delaval will continue to maintain their posi-tions concerning acceptability of the fire rings pending the results of a year of, experience. .
- I have fo narded three copies of the agreement to Mr. Bowman on the assumption that he will proceed to have them executed.
to Mr. Zbinden I have asked that he return these executed documents together with invoices in the appropriate amounts. Upon execution of the agreement, checks should be prepared in payment of the invoices and delivered to Mr. Zbinden to be ex-changed in either his office or our office for the necessary release from Delaval.
Commissioner Donald Harris May 19, 1978 Page 2 I believe the State should issue a check to Delaval in the sum of $23,895.64 and return the valves to Delaval for credit and issue a check to Lockheed in the sum of
$23,957.99 which.it will be obligated to deliver to satisfy 3 Delaval. .
Once this transaction has been. accomplished, I believb it would be in order to make payment to Lockheed of $201,751.96 in accordance with the memorandum of understanding of,J,anuary-5, 1978. I will be out of the city the rest of this month except for Tuesday, May 30th, and will then be out of the country until the end of June. Bruce Babbitt will be able to take care of any matters which may come up during that time. Very truly yours, FERGUSON & BURDELL , fDonald4 /c b By: McL. Davidson DMD:nl . CC: Mr. David Bowman Mr. Max Zbinden I e
law CartCES CF i was em rtmowSON Ferguson e Burdell
"=a a ES S MupOFLL [ig?3) 1700 peoptts maisoNAI. SANn aus60iNC C.* Smsw. sa.
or cow =*ew l0 0 O'd'Tf; ~ Seonfe%dingca osm 3-;'; A,;ge at J agtm&N ggggn=ONE (206I 622 t?te SCo?? m OS90e%E westram a eaoone TELtcopiER (Joel 682 6078 0 O swao Seeg emasO
, *l.l: T*.'.'. 7 "*"'*~ ..steau o ave +ts ~ %5' ".'7;2" May 19, 1978 Mr. David Bowman Lockheed Shipbuilding & Construction Co.
2929 - 16th S.W. Seattle, Washington 98134 Re: State of Alaska - Lockheed
Dear Dave:
Enclosed please find the original and three copies of the Lockheed - State of Alaska agreement related to the engines which has been redrafted in accordance with our conference, together with a copy of my letter to Commissioner Harris and Max Zbinden. Very truly yours, FERGUSON 4,BURDELL
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/ i f u//1 By: Donald McL. Davidson DMD:nl Enclosures CC: Commissioner Donald Harris Mr. Max Zbinden l
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AGREEMENT i THIS AGREEMENT made as of , 1978, by and between LOCKHEED SHIPBUILDING & CONSTRUCTION CO. (hereinaf ter sometimes referred to as "Lockheed") and the STATE OF ALASKA (hereinafter sometimes referred to as
" Alaska"),
E I I E g g S E g g: WHEREAS, Alaska and Lockheed heretofore entered into a contract for the construction of M/V COLUMBIA, known as Contract No. MT-141; and WHEREAS, Lockheed and Delaval Turbine, Inc. (Engine and Compressor Division) entered into a contract whereby Delaval agreed to furnish main populsion machinery; and WHEREAS, disputes have arisen between Alaska and Lockheed concerning compliance with the contract of the machinery supplied by Delaval, and Delaval has furnished materials for repairing and maintaining such engines for which it has invoiced the State of Alaska for $162,852.63, as more fully described on the list attached hereto marked Exhibit A and incorporated herein, and the State of Alaska has refused to pay the same; NOW, THEREFORE, in consideration of the premises , and mutual covenants and conditions hereinafter contained, and of Ten Dollars ($10.00) and other good and valuable
. . consideration by each of theparties to the other in hand paid, receipt whereof is acknowledged, the parties agree as follows:
- 1. Th3 Stata of Alacks cgreco to rccognizo Purchase Order No. 564679, Invoice No. 13868, in the-amount of $23,895.64 and agress to pay the same and to return to Delaval's Seattle office 12 exhaust valves for credit on Invoice No. 12301 in the amount of $1,744.43; and
- 2. The State of Alaska agrees to pay 023,957.99 to Lockheed provided Delaval agrees to accept the same in.
full settlement of all the remaining invoices contained on Exhibit A and furnishes evidence of satisfaction of the same by release of the State of Alaska.
- 3. Lockheed and the State of Alaska agree that the following provisions will govern resolution of Alaska's claims for presently known deficiencies in the engines:
(a) Turbo Chargers. The State of Alaska will consider the turbo chargers to meet contract require-ments and problems heretofore encountered with them as solved, provided: (1) Three out of the four turbo chargers operate for 4,000 hours without breakage of a nozzle ring; (2) Three out of the four turbo chargers operate 4,000 hours without buildup of deposits which cause imbalance or which require cleaning and rebalancing; and (3) All four turbo chargers operate satisfactorily at low engine RPM's and otherwise in accordance with specifications during the 1978 season of operation of M/V COLUMBIA. The foregoing requirements for resolution of the parties' dispute concerning the turbo chargers are based upon normal operations and maintenance of the l l.
l 1 turbo chargers in acc rdtnce with D31aval rccomm:n- I dations. I (b) Cracked Engine Heads. Lockheed will ' furnish or cause Delaval vendors to furnish replace-ment ABS engine heads of Delaval manufacture to Alaska without cost at Seattle of'the improved manufacture and design as replacement of any engine heads which crack er otherwise prove defective during operations of M/V COLUMBIA up to March 31, 1979. Any cracked or defective cylinder heads will be returned to Delaval at Seattle, In the event no newly designed and manufactured heads crack during normal operations during the 1978 season of operations of M/V COLUMBIA, the. State of Alaska will consider the engine heads to meet contract requirements and problems heretofore encountered with them as solved, subject to replacement of cracked heads as herein provided. (c) Fire Rings (Head Gaskets). Delaval has and is undertaking continued improvements of the engines and particularly of the fire rings. Alaska will continue to monitor the suitability of existing fire rings based upon representations of Delaval that. existing fire rings are manufactured of the most suitable material commercially available and have proved suitable in service on similar engines. Lock-heed will furnish and caase Delaval to furnish any information concerning improved fire rings available to either of them as of one year from the date hereof, Alaska reserving its claims concerning acceptability of the fire rings pending the results of such monitor-ing and Lockheed and Delaval reserving their claims that the same are acceptable. 1
- 4. This Agrosmsnt doas not waiva, limit, releaso 4
or affect any of the rights of either of the parties hereto as the same now exist, particularly including, without limitation by reason of enumeration unresolved claims of the State related to propellers. DATED at Seattle, Washington, this day of , 1978. LOCKHEED SHIPBUILDING & CONSTRUCTION COMPANY By STATE OF ALASKA By f f i i
EXHITIT A
' UNPAID DELAVAL INVOICES M/V COLUMBIA P. O.
INVOICE
;;E NUMBER NUMBER COMMODITY AMOUNT 5-75 H. Mcdonald 09170 Turbo Parts . 987.80 3-75 551945 10161 Turbo Parts 2,877.80 5-75 551945 10971 Freight on Inv. 610161 33.39 '4-74 H. Mcdonald 11015 Exh. Flange 143.40 2-76 562493~ l Cyl. Head 8,087.00.
2-76 563714 13176 Rings, Liner Seals, etc. 1,428.75 2-76 563714 13198 Rings,. Gaskets, etc. 10,513.80 2-76 563714 13338 Freight for Inc. 813198 48.57 3-76 563714 13301 12 Exh. Valves 1,744.43
- 0-76 563714 14145 Turbo Parts 1,743.90 0-76 563714 13487 Turbo Parts 1,641.85 6-76 Desru-Meaux 13639 Frt. Only on New conrod 216.55 2-76 H. Mcdonald 13752 Lockwire & Head Gasket 180.82 7-76 564662 3 Cyl. Heads 25,473.00 1-76 56413 13860 2 Cyl. Heads 16,982.00 9-76 56413 13966 Frt. for Inv. 413860 1,118.00 1-76 564679 13868 Complete Turbo 23,895.64 **
7-76 H. Mcdonald- 13935 6 Cyl. Head Gasket Sets 578.63 1-76 592404 14203 1 Line Cyl. 2,277.72 3-76 564750 14080 2 Pistons 9,042.84 4-76 592523 14176 Cyl. Head Gaskets 99.90 4-76 592523 14374 2 Seals 53.00 6-76 592593 '.4487 Frt. Ch7s. Omitted on Inv. 814374 13.65 6-76 592514 14185 1 Cyl. Head 8,491.00 6-76 592518 14606 Frt. Chgs. Omitted on Inv. #14185 597.86 1-76 592514 14269 2 Cyl. Head Assy. -Frt. Chg. 17,706.63 2-76 592514 14438 Remaining Frt. for Inv. 804269 136.55 3-76 564662 14313 3 Cyl. Heads 26,738.35 TOTAL $162,853.63
- Valves to be returned direct to Delaval for full credit
** To be paid direct to Delaval
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- ""5 A Trarmtnerica Comntly November 28, 1978 Alaska Marine Highway Pier 48 Seattle, WA 98104 Attention: Mr. Max Zbinden Project Engineer
Reference:
M/V Columbia DMRV-16-4, S/N 72033-34
Dear Max:
This note will serve to confirm verbal recommendations we made during our 11/21/78 meeting. Exhaust valve cam timing should be advanced (not retarded) five (5) camshaft, ten (10) crankshaft degrees to reduce intake valve head and stem deposits. The camshaft and exhaust cams should be i
' scribed in a manner suitable to index each exhaust cam in the advance direction 0.175 inches on the camshaft diameter. Once the exhaust cam has been moved ten (10) crankshaft-degrees, the valve timing will be as follows: ,
Intake Opens 75 degrees BTC Intake Closes 25 degrees ATC Exhaust Opens 60 degrees BBC Exhaust Closes 40 degrees ATC This exhaust valve timing change is expected to improve the turbo performance also and' therefore, our previous recommendations to reduce nozzle ring area in the turbochargers is retracted. If cruise speeds of the si'ip are set in the future to require something' less than full er.gine power, a reduction in nozzle ring area might be ecommended. For the purposes of checking the present nozzle ring area (designed for 39 sq. in.) please gauge the blade openings at mid-blade length. The gauge opening should be 0.354 inches. Bob Gray can assi-t in this check. With regard to John Barich's item #7, John was commenging on the nozzle tip change. Thepreviousnozzletipswe5e 50 by .019" spray hole diameter, while 0 the new tips are 140 by .02 hole diameter. The present 140 tips bring the spray hole size back to the original diameter and shculd require approximately tha same fiJ11 power rack stop position. We should arrange to check this out during
. DELAVAL TURBtNE 6NC.
, . , m . _ - , . . -, ,. , - - - _
W Il A Transamenca Comcany 62 Alaska Marine Highway Fevember 28, 1978 Page Two the shake down trials in February,1979. Attached is the limited information we received from the Kraissi Valve Company. Kraissi's A1710 brochure reccmmendations call for a bypass connection between filter cases, similar to the line sketched in on the attachment made to my November 17, 1978 corres-pendence. We have available a modified cylinder head containing a stiffening member at the 3 and 9 o' clock positions as well as stiffer side pla tes. If this head could be installed on one of the er.gines and watched carefully for satisfactory fire gasket perfomance, Delaval will be pleased to supply the head for this purpose. The head would have to he lifted at approximately 1,500 hours operation in crder to check the gasket conditions. Your ccmment on such a test would be appreciated. I trust the foregoing is in substantial agreement with verbal coments made during out November 21 meeting. I discussed the condition of the starboard engine idler and cam gears with Bob Gray yesterday and it was his opinion that these gears were in excellent condition and suitable for operation against a new crank gear. Bob returned three exhaust manifold expansion joints and several piston ring sets during his visit over Thanksgiving dnd we plan to press our vendors for their respective . Cements. We are looking for,vard to receipt of the starboard engine crankshaf t gear, con rod bolts found with chip threads, valves with stem chrcme separation and any main or connecting rod bearing shells on which you might want more formal ccm ent. John Rountree called your office yesterday to bring you up-to-date on delivery of heads, pistons and liners. We will continue to press the shop for improvement'of the delivery of the several items, particularly the second set of pistons. Very truly yours, DELAVAL TURBINE INC. Engine and Compressor Division
/ -
G. E. Trussell ow Manager, Custcmer Service
TIMING DIAGRAM C.W. ROTATION
- Non Reversible Model"R & RV" Turbocharg.:d Diewt Engine witn Four Valve Head FIRING ORDER l INTAKE AND EXHAUST VALV 16 Cyl. RV-1 L-8R-4L-5R-7L-2R-3 L-GR-8L-iR-5L-4R-2L-7R-6L-3R Velve Lift -- 1.230 en. Less Crearar Opening Rarno Lif t at Valve - .CS
, 12 Cyl. RV-1 L-6R-5L-2R-3L-4R-6L-1R-2L-5R-4 L-3R Closing Ramp Lift at Valve .05: 8 Cyl. R 4-7-3-8-5-2-6 VALVE CLEAR ANCES COLD 6 Cyl. R 5-3-6-2-4 Intake .04t Exhaust .041 NOTE: Cylinders are numbered from front of engine, or gear case end, to the rear I - ^ ~ ~ ~ wim No.1 cylinder always farthest from the flywheel. Banks are right or ., lef t as viewed from flywheel end. { [_ ,_ _
- T. O. C.
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Tohn 2s-ich 28 July,1978 neluwel 'egine & Corapressor Div
., i) y Max Zbinde jj ,
M/V COLU2GIA Cylinder head removal. Alaska !!arine;_fighuays Pier 43 1 i i As per your rehuest, Ihe follouing is a listing of cylindars from which heads have been removed so far during this acacon (15 week =). It does not include tha 57 head, SIC, that una found cracked and changed out just price to the vescel: c return to operation: S:E: 35, 5-13-73 ME: 06, 6-16-78 GS, 6-23-78 02, 6-30-78 09, 7-17-78 99, 7-14-73 910, 7-17-73, Two of our three spare heads have been shipped to your facility for inspection, ec. The third head in aboard the vessel and is one of the two pulled en 7-17-78. He cleaned it up and are holding it as a spara until one of the others comes bach. .. does not have tel-talk holes as does one other on an engine. t I l i l I e
ALASXA. [ 7 I /
"3 Ii! ugh Mcdonald DA ' E 15 June, 1978 Port Engineer 5o e.o
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' N 'd Luanct Main Engines Kenneth E. Bese.lin . .,
Chief Engineer 3 M/V COLUMBIA "B" Crew Deterioration of fire seal rings continues at an ever increasing rate, as we now have five leaking Cyl heads P&S Mains. We will attempt to change out one Cyl head in Seattle, and it would appear this will have to be repeated each week until a solution can be found. As I have reported in the past, the blowby across the gasket surfcce of the Cyl head causing metal etching thereby decreasing the life of the fire ring each Cyl head change out. Lube oil filter life on the Stbd M.E. has now fallen below 40 hrs and June 12th we switched over to a sock filter to see what difference, if any, these filters will make. I have stated from the start of this problem that in my opinion the cause of the short life of these filters is caused primarily by blow by of pistons and valve guides. Furthermore, I can not agree with the whitewash report by Mr. Durie of Enter-rise, dated May 11, 1978, nor do I agree with the opinion that water cculd be the most prooable cause of short filter life. Please note - The Stbd M.E. has had priority purificatien time since we left lay-up March 31, 1978 with 48 hrs seperator time Stbd M.E. and 24 hrs Port M.E. Please note analysts Inc. report May 24, 1978 Stbd M.E. % water 494 Port M.E. % water 690, yet the filter life on the Stbd M.E. was around 40 hrs at this point and the Port M.E. filter life better than 200 hrs. At the present the Port M.E. filter has been in operation better than 210 hrs and still going with only 1/3 seperating time while the Sthd filters were switched # 39 hrs. The L.O. seperator was completely torn down this trip and cleaned, refitted with new seals and gaskets and put back into operation on the Stbd M.E. The ring dan presently being used is 127 mm We tried a 140 mm ring dam but could not maintain a. seal. Past practice has been to shoot the seperator every 4 hrs, but because of build up of carben on the ring dam indicating overloading of bowl capacit/ we are presently shooting the seperator every 2 hrs, also we have reduced throughflow to 450 gals per hr in order to try and improve on seperator operation. We have taken samples of the sludge shot both on a 2hr shot and 4hr shot into a bucket for observath It would appear that the seperator is doing the job it was designed for but chac the oil has excessive amo'unts of carbon in it. There seems to be enough solid carbon deposits in one 2hr sludge shot to completely fill one P-I filter. We are conducting more tests on ring dam build up and will have this information on arr. Seattle. To date, we have lost three SS Exhaust bellows on the Main Engines due to bur'nout the last one while I was aboard. Upon ucroval ic was found that Enterprise had instati the bellows the wrong end to. When this was brought to John Baries attention he infor-me that the bellows would onl/ last about 2000 hrs anyway. This was news to ce as it means that every 2000 hrs we shall spend $11,200 to change out bellows. I experienced some problems with the rack sticking on the Stbd M.E. outboard each my first week aboard. #1 & 8 fuci pumps seemed to be the worst. We changed out #1 fu, pump and to this date have had no more problems with this Engine. l 1 1
5-18-73 C/2 M/V CCiC dIA Max Zbinden Main and Aux Diesel Engines Pier 48 Attached is lettar from Delaval concerning the borescope and base inspection made on the main engines for your information and filea. Also attached are the results of the =ost recent main engine oil analysis which I received via telephona on 5-17-78. These samplec were drawn from a new sampling point uhich actually reflects the crankcase oil before any filtratica has taken place. It clearly indicates that we have a unter leak in the SHE and which is the most probably cause of the short oil filter lifs. Coul<1 he associated with one or both of the original cylinder heads still on the SME (enes without tel-tale holes) or some others. Suggest that these heads be changed.out ASAP and a close check be maintained on the others to see if we can determin the source of any other water leaks. Until resolved the SME shoe'sd received priority purification time. I have requested Waukesha EngLne Co. provide us with a set of Wierstat Thermostats 0 (10 each 190 and 2 each IS00 thermosta'ts) for installation in the #2 generator engine. This set up is the same as presently in the #1 and 93 units. They will be in Scattle for installation next week. I have another water box in the warehouse that Vaukesha furnished, however, I see no point in installing it since the original unit was tested and found not to leak. Vaukesha did request that we obtain the teep of the #2 engine bypass water before we change out the thermostats. This uill re- ' quire the installation of a boss for the thermometer. This is a must item. i
LAW MIMS Of wes.M rcsonusom c Davec spEs pano - E.p swain,are
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14crquson & lhurdell 1"ASC!"et? "'"' "'#2?",^3'/""'" ; 1700 6*8t0 4f. ?4 I totaAL DAN A ltUfL0neo O A 90 4L n, ou LpgA e e7 O vt3 N ,e hoHlc,Y[0I1tnglonOdIU rn ve. o e a cure, 5 en ae.C . J 4 N J L t, s , p TCL* e,.co 4C 430 62? 47se 1CLCco. effe wo6' t>02 6G78 January 19, 1979 Commissioner Donald Harris Department of-Public Works State of Alaska Pouch K - State Capitol Juneau, Alaska' 99811 Re: Alaska - Lockheed
Dear Commissioner Harris:
I have had no communication of any nature whatsoever with Lockheed and Delaval since last August. 'It would seem.to me that there will very soon be inquiries made concerning a number of subjects covered in the June 19, 1978 agreement. The question will arise, I suppose, as to whether or not the turbo chargersmeet the standards set forth in the agreement which contemplated 4,000 hours of operation and trouble-free operation per the specifications during the 1978 season. 1 The agreement also provided that the engine heads could be considered in compliance with the contract if no newly designed i and manufactured heads cracked during normal operation during 1978. There may also have been some factual determination made concerning the fire rings. For your information and convenience, I am enclosing an extra copy of the June 19th agreement. There is also an open question over the memorandum of understanding of January-5, 1973, with Lockheed. That was the agreeme.at whereby all claims were either settled or provision made for settlement, except the State's claim upon the propeller blades and Lockheed's claim to an agreed upon reserved contract balance of $40,000.00. I believe that the Delaval matter provided in paragraph 3 has been resolved;.that the State has resolved any problems with Waukesha under paragraph 4 and that payment has been made under paragraph 6. This would still leave open then the question of the study of the propellers and the obligation to pay Lockheed $40,000.00
. Concaicsioner Donald IIarris January 19, 1979 Page 2 unless the study shows the necessity for a propeller replacement and a possible replacement claim against Lockheed of $170,000.00.
I mn a little concerned that the State proceed with the making of the study and carrying out the agreement promptly so that there could be no issue raised by Lockheed of a waiver of rights or a delay in exercising them which woald prohibit-recovery of costs of replacing the propellers. I am enclosing a copy of the memorandum of under-standing for your convenience. I would appreciate it if you would advise me as to j whether or not there is anything we could or should do in connec-j tion with any of these matters. ? Very truly yours,
+ FERGUSCN & BURDELL .
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hy By: Donald McL. Davidson' DMD:nl Enclosures CC: Mr. W. R. Hudson Mr. Max Zbinden l l l _ _ _ .. __m
January 5, 1978 MEMO OF UNDERSTANDING ON PROCEDURES At the conference on January 5, 1978, it was generally agreed that the parties would settle their differences concerning the MV Columbia.
- 1. It was agreed that the contract balance was
$401,751.96.
- 2. The State of Klaska would settle all claims asserted in its letter of June 8, 1977 (except the propeller blades item) for $200,000.00 subject to satisfactory resolution of the following items or agreement on procedures. *
- 3. The State, Lockheed and Delaval Enterprises reach a mutually satisfactory agreement whereby Lockheed assigns its contractual rights against Delaval, if any, to the State and Delaval undertakes formal committment to the State to continua i
its efforts concerning the main engines, including satistactory proot of the resolution of the turbo-charger problem, replacement of cracked-heads with the now heads, release of outstanding invoices ($162,853.63), and satisfactory resolution of unsuitable fire rings (head gaskets) together with a suitable warranty for new parts or known design problems, limited, however, so as to exclude ordinary wear and tear and maintenance which would
normally ba expected.
- 4. Lockheed assigns is contractual rights against Waukesha, if any, to the State.
- 5. The State will retain $40,000.00 to cover the cost of a propeller study and reserves its rights to recover replace-ment costs of 16 propeller blades up to $170,000.00 and Lockheed reserves its rights to claim such $40,000.00 - both parties reserving all of their rights respecting propeller blades but agreeing tolimittheexposure(to$210,000.00.}TheStateagrees to pay over to Lockheed the difference if the study cost is less than $40,000.00 and agrees to make such study available to Lockheed.
l The State will institute such study with all reasonable dispatch and presently believes such study can be complated in six months.
- 6. Upon satisfactory resolution of the procedures out-lined above the State shall be obligated to pay fockheed $161,751.96 which payment shall discharge all of the State's obligation te Lockheed relating to the MV Columbia, except Lockheed's claims to the S40,000.00 withhcid under paragraph 5 and the State shall discharge Lockheed of all of the State's claims against Lockheed relating to the MV Columbia excepting its claim for study costs and replacement propeller blades, if required, but limited to S210,000.00.
-2.
- 7. The partics hereto undertaks to coopsrativaly and expeditiously seek to carry out this understanding but i l
I this memo is not itself an enforceable contract and shall not ; lua deemed an admission by any party or be evidence against a party, but is intended to reflect conclusions reached at the settlement conference and to be a continuation of settlement efforts. Dated January 5, 197.8, at Juneau, Alaska.
/s/ Donald McL. Davidson /s/ David B. Bowman Donald McL. Davidson David B. Bowman Attorney for the State of Attorney for Lockheed Alaska 4
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ll/ AGitEEMENT !O P/ TIIIS AGREEMEMT made as of JObb k9 , 1978, by and between LCCKHEED SHIPBUILDING & CONSTRUCTIO:t CO. (hereinaf ter sometimes referred to as "Lockheed") and the STATE OF ALASKA (hereinafter sometimes referred to as
" Alaska"),
E E 1.E E E E E E E: WHEREAS, Alaska and Lockheed heretofore entered. into a contract for the construction of M/V COLitMBIA, known as Contract No. MT-141; and WHEREAS, Lockheed and Delaval Turbine, Inc.
~
(Engine and Compressor Division) entered into a contract whereby Delaval agreed to furnish main populsion machinery; and WHEREAS, disputes have arisen between Alaska and Lockheed concerning compliance with the contract of the machinery supplied by Delaval, and Delaval has furnished materials for repairing and maintaining such engines for which it has invoiced the State of Alaska for $162,852.63, as more fully described or the list attached hereto marked Exhibit A and incorporated herein, and the State of Alaska has ro'used to pay the same: NOW, THERETORE, in consideration of the premises and mutual covenants and conditions hereinaf ter contained, and of Ten Dollars ($10,00) and other good and valuable consideration by cach of thcparties to the other in hand p:id, roccipt whereof is acknowledged, the parties agrco CS [Olloue* 1 1
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- 1. Tha State of Alaska agress to recognize Purchase Order No. SG4G79, Invoice No. 13868, in the amount of $23,895.64 and agrees to pay the same and to return to Delaval's Seattle offico 12 exhaust valves for credit on Invoice No.13301 in the amount of $1,744.43; and
- 2. The State of Alaska agrees to pay $23,957.99 to Lockheed provided Delaval agrees to accept the same in full settlement of all the remaining invoices contained on Exhibit A and furnishes evidence of satisfaction of the same by release of the . State.of Alaska.
- 3. 'Lockheed and the State of Alaska agree that the following provisions will govern resolution of Alaska's claims for presently known deficiencies in the engines:
(a) Turbo Chargers. The State of Alaska will consider the turbo chargers to meet contract require-ments and problems heretofore encountered with them as solved, provided: (1) Three out of the four turbo chargers 4 operate for 4,000 hours without breakage of a nozzle ring; , (2) Three out of the four turbo chargers operate 4,000 hours without buildup of deposits b which cause imbalance or which require cleaning and rebalancing; and (3) All four turbo chargers operate satisfactorily at low engine RPM's and otherwise in accordance with specifications during the 1978 season of operation of M/V COLUMBIA. The foregoing requirements for resolution of t the partion' dinpute concerning t!ic turbo chargers are l based upon normal operations and maintenance of the l l I l l l l
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turbo chargers in accordance with Delaval recommin-dations. , (b) Cracked Engine Heads. Lockheed will furnish or cause Delaval vendors to furnish replace-ment ABS engine heads of Delaval manufacture to Alaska without cost at Seattle of the improved. manufacture and design as replacement of any engine heads which. crack or otherwise prove defective during operations of M/V COLUMBIA up to March 31,.1979. Any cracked or defective cylinder heads will be returned to Delaval at Seattle. In the event no newly designed and manufactured heads crack during normal operations during the 1978 season of operations of M/V COLUMBIA, the State of Alaska will consider the engine heads to meet contract requirements and problems heretofore encountered with them as solved, subject to replacement of cracked heads as herein provided. (c) Fire Rings (Head Gaskets) Delaval has and is undertaking continued improvements of the engines and particularly of the fire rings. Alaska will continue to monitor the suitability of existing fire rings based upon representations of Delaval that existing fire rings are manufactured of the most suitable material commercially available and have proved suitable in service on similar engines. Lock-heed will furnish and cause Delaval to furnish any information concerning improved fire rings available to either of them as of one year from the date hereof, Alaska reserving its claims concerning acceptability of the fire rings pending the results of nuch monitor-ing and Lockheed and Delaval reserving their claims that the name are acceptablo.
- 4. This Agreement does not waive, limit, release or affect any o" the rights of cither of the parties hereto as the same .now cxist, particularly including, without limitation by reason of enumeration unresolved claims of the State related to propellers.
DATED at Seattle, Washington, this f day of dO% , 1978. 1 li LOCKHEED SHIPBUILDING & CONSTRUCTION COMPAN'l By // h[/ll k N M v DAVID B.80W?.!AN Mcrebry STATE 05 ALASKA
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/? -Ge . ..e ..*'s ei UNPAID DCLAVAL IllVOICES $ '?' ~8
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- ::UM3CP. NUMDER COM:4CDITY /.f!602:7
-75 H. Mcdonald 09170 Turbo Parts
- 987.80
-75 551945 10161 Turbo Parts- 2,877.80
-75 551945 10971 Freight on 'Inv. 510161 33.39
-74 H. Mcdonald 11015 Exh. Flange 143.40
-76 562493 1 Cyl' Head
. 8,087.00
-76 563714 13176 Rings, Liner Seals, etc. 1,428.75
-76 563714 13198 REngs, Gaskets,etc. 10,513.80
-76 563714 1333! Freight for Inc. 213198 48.57
-76 563714 13301 12 Exh. Valves 1,744.43 *
-76 563714 14145 Turbo Parts 1,743.90 76 563714 13487 Turbo Parts 1,641.85 75 De sru.-Meau.4 13639 Frt. Only on New Conrod 216.55 76 H. Mcdonald 13752 Lockwire & Head Gasket 180.82
-7 E 564662 3 Cyl. Heads 25,473.00
-75 56<13 13860 2 Cyl. Heads 16,982.00
-76 56413 13966 Frt. for Inv. 813860 1,118.00
-76 564679 13868 Complete Turbo 23,895.64 **
-76 H. Mcdonald 13935 6 Cyl. Head Gasket Sets 578.63 -76 592404 14203 1 Line Cyl. 2,277.72 -76 564750 14080 2 Pistons 9,042.84 75 592523 1417G Cyl. Head Gaskets 99.90
~i Ek2523 14374 2 Seals 53.03
-!! 592593 14487 Frt. Chgs. Cmitted on Inv. #14374 13.G5 -76 592514 14185 1 Cyl. Head 8,491.00 -76 592514 14GOG Frt. Chgs. Omitted on Inv. 514105 597.85 -76 592514 142G9 2 Cyl. IIcad Assy. -Frt. Chg. 17,706.63 -76 592514 14430 Remaining Frt. for Inv. 0042G9 136.55 -76 564662 14313 3 Cyl. Ileads 26,73tt.35 TOTAL $1G2,053.G3
- Valve :. to lic returned direct tc Delav.il for f ull credit
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DEPANT.'.;ENT OF TR ANSPORTATION AND PUBUC FAQ iTE.S 17 j- - i.myre.vv.czx.v c?zii.ma,.s c:wsiava= v.mnu::cwaysrms.w ] I t{yf. January 7.] l
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Donald McL. Davidson Ferguso- & Burdell
' ' /; / M ARIN': D'N4y f##ISICh o 1700 Peoples National Bank Building EMS Seattle, Washington 93171 Subj: Alaska--Lockheed; M/V C01.UM3fA
Dear Mr. Davidson:
In regards to your letter of January 19, 1979, to_ Ccica:issioner Canald Harris, please be advised that the ne.i Corrr.iissioner is R.W. liard. Additionally, there is no langer a Department of Public War':s. The current title is Cocaissioner, Department of Transportation and Public Facilities. With respect to the provisions contained iri Section 3 of the June 19, 1978, agreenent, the status to dat is as follows, refcrring to the sub-paragraphs as numbered in the agreeaent; 3 (a)---The two part main engine tur'cochargers have thus far accumaiulated 3010 hours of operation and the tw6 (2) starboard main engine turbochargers have accuiiciulateJ 3022 hours of operation since inadification of the nozzle ring assenbly and installation or the air seal assembly. All four turboch2rgers have thus far operated satis-factorily and without abnon:al deposit build-up on blading and without icbalance problems. Operation at low engine rpm's has also beca satisfactory. M/V CO:.UMBIA is scheduled to resum.e service on Fco-ruary 23,1979, after which the remainder of the re-quired 4000 ha >rs of sa tisfactory turboch2rger operation can be accu;.::;uieted. 3 (b)---The raatter of cracked or otharwise defcctive cylin::er heads remins outstanding. The detai!s are_ involved and will be handled by separate corrc pondcoce. 1 J
Danald Mel. Davidson J a nu.r, y 24, 1979 Fergusori & Curdell Page~II. SUD.): Alaska--Lockheed; IVV COLUMBI A---(Cont'd)' 3 (c)---The saatter of Fire Rings (head gaskets) iws not been resolved. . It raight be that the fire . rings, currently used,would be satisfactory if it were r.ct for an apparent cylinder head design and/or structural de-ficiency. The specifics of this probleir. will also be. handled by separate corresr.ondence. The re:.-ainier; portions.of the a ;rce.aent regarding pay-ments to DeLavel and Lockhee ! plus the return for credit of twelve (12) ccch er.hsust valves bas been carricJ out.
..s h'ith respect to the memorandu::: cf understanding of I'
January 5,1978, with Lockheed, be advised tha t the i propeller study is currently underh.:y through Ccncract fH-240 wi th flicku.m f Spaulding Associates, using the services of the Canish Ship Pesearch Laboratory. The project was started in ikrch,1970, and was to be cor:- pleted in October,- 1978. Hov;ever, since date: on bin & design and edge definition could nat be-obtains:i frc.-- Lockheeds subcontractor, Allis:Chalraers, who :er.ufac-tured the original blades, it v.as n::cessary that thir data be taken from our spara set of blades. This re-sulted .in lengthy delays and the t a,ised cc:npletion date is now iby,1979. The cost thus faria3sociated with the DSRL testing is $33,937.00, to which can br: added the cost of flickum f. Spaulding Associates Con-tract MT-240 plu : the cost of obtaining the blada dab through Coolidga Propeller, which uill bring the cotei i cost of the project well above the $50,C00.001, retcin-ed for the study. 4 Sincarely,
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Proie M Engineer Alaska ibrina liigh.tey Pier '!C 5ca ttl e, ' ::sh iag ton e"; ni , MEZ:abh CC: R.l!, Kird/ Con.nissioner - 1.'n . HuJea/Di rec tor y Merv Grigg. //. !s in i<.t.ra tive Of T i< .f - A. ii. Mc.lbani d/ t'..r t !ngineer L' .
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.,'*A .V~EhAid:AhO CfERATICss5 ClVSCNOF *,fMINEHIGWA YSYSTDG January 31, 1979 DeLaval Engine & Compressor Division 550-85th Avenue P.O. Box 2161 Oakiand, California 94641 A TTN: Mr. Dick Desrumeaux SUBj; M/V COLUMBIA; Part shipment
Dear Mr. Desrumeaux:
The following information is furnished concerning return of incorect or defective parts to DeLaval for disposition as noted below.... One (1) box. ..MARKE0-RMR-5731-55/contains one (1). cylin' der head, ser-ial =X22, wherein valve seat to valve guide concentricity is at least
.011" out. Request repair and return ASAP. It should be noted that the majority of the heads repaired and returned to date by DeLaval have had the same problem, requiring hours of crew labor in grinding before the valves can be lapped in. Head X32 is the worst condition.
This sa:.e box contains two (2) sets of new piston rings which were fcund defective and rejected for use. M/V COLUMBIA'S account should be so crediced. One gl) box.. .f".RKED-RMR-5731-56/contains one (1) cylinder head, serial nil 5, wherain it was received from DeLaval following repairs without the acdition of tell-tail holes and the gasket face damaged by a gouge. This head to be repaired and returned ASAP. Two '2) boxes...t!ARXED-RMR-5731-57, each containing one (1) newly fur-nished cylinder liner receivea with Parkerized finish in lieu of machine hone finich. Liners are being returned for exchange by new liners of proper finish A5AP. One (1) ocx...MA9xED-EMR-5731-58 containing two (2) engine sets of con-nectiig rod bearings. These 13" bearings were incorrectly furnished by DeLaval lr.1ieu of 12" bearir.g used on M/V COLUM8IA. Returned for credit. One (1) 50x... MARKED-RMR-5731 47, containing one (1) each turbocharger e>.haus! #1ex section incorrectly furnished by DeLaval . Returned for credit.
- p. A.T s /ta, .
DeLaval Engine 1 Compressor Division January 31, 1979 A TTtt: Mr. Desrumeaux Page II - Cont'd
'JP.J : M/V C'] LUM 3I A: Part shipnent One (1 ) box. . . MARKED-RMR-5731 /.0, containing one (1) new cylinder head, serial D'59, furnished last year on consigrment for use as back-up emergency spare. Returned to DeLaval to clear consignment record.
One(1) box... MARKED-RMR-598 , containing one (1) new cylinder liner, one of two ordered at the beginning of last year as vessel spares and furnished with Parkerized finish. Liner being returned for exchange by new liner with proper machine hone finish ASAP. On~d) box. . . . .MARXED-RMR-5731-4/, containing thirty two (32) new ex-haust valves, 02 style. We inadvertently incorrectly ordered 02 valves as exhaust valves wherein, based on instructions received last year, we were to use 04 valves as exhaust valves and 02 valves as intakes. Ap-parently your parts department did not catch our oversight. Since we have adequate 02 valves on hand, the 32 new 02 valves are being returned for credit. Replacement of 04 valves will not be ordered until such time as this 02 vs Oa valve problem is resolved. To date.. .we still have not received the four (4) push r.cds ordered by us in Octooer,1978, are still awaiting receipt of twenty-two (22) con-necting rod bearing halves and sixteen (16) piston pin snap rings, that we inadvertently left in the pistons sent to DeLaval for modification, hich were nat returned with the pistons. Sincere'ly, 4 3
. gli/h .gSc: L<!
Max E. Ainden Project Engine Alaska Marine Highway Systems MEZ:abh CC: W:. Hudson' Director-Alaska Marine Highway D. McL. Davidson/ Attorney Onuglas t'arti i/n General Manager /DeLaval , R.J. Pacers /Ganeral Sales Manager /DeLaval
'1. A. R"o Mes/Engir.eering anager/Delaval G.E. Trussell/":nyter Custoer Service /Cei.aval T. Eiaen/ District Manager /DeLaval Chief Engine nr!" '.' COLU.91.A l
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I _ b l = k # # ""0* "'" DEPAR'iNENT OF TR ANSPORTATION AND PUBLIC FACILITIES ., AtAINTENAhCEAND tXYERATICt3 DIVISIONOFMARINEHIGHWA YSYSTEa6 February 2,1979 Mr. William Hudson / Director Dept. of Transportation and Facilities Div. of Marine Highway Systems Pouch R Juneau, Alaska 99811 SUBJ: M/V COLUMBIA Main Propulsion Engines
Dear tir. Hudson:
A. The purpose of this letter is to update you on the' status of M/V COLUM-BIA'S DeLaval Main Propulsion Diesel Engines and to furnish details relating to cylinder heads and firing rings as noted in my letter of January 24 1979, to Attorney Davidson. I have indexed the various sections for ease of future reference. B. Just prior to the start of the 1978 season, #7 outboard liner and piston on the starbcard engine were pulled and changed out due to heavy scoring caused by chrome plating failure on the upper piston rings. Signs of blowby were evident. Upon reassembly, it was,, found that the associated cylinder 1 red was cracked through the valve bridge. The cylinder head was shipped to DeLaval for repair and return. The removed liner plus two (2) used liners, previously changed out, were also shipped to DeLaval for possible rework. Only one of the three (3) liners could be salvaged and was so done and two (2) liners pcocured as spares. C. During the first weeks operation on regular service, air was observed in the starboard main engine jacket water expansion tank indicating either a cracked cylinder head and/or blown fire rings. During the second week, the s'tarboard main engine lube oil filter had to be changed out after lh weeks operations even though we had changed the oil prior to the~ start of the season. The second set of filters lasted only one (1) week. This condition had been experienced during the prior season and had been brought to the attention of Delaval without' any satisfactory resolution. Pming the first 15/ weeks of operation a total' of seven-(7) cylinder heads were removed because of defects or blown fire rings. By the time the wssel aas taken out of service, we had used all three (3) 'of our spare tieads, and were using heads furnished by DeLaval on consignment, including d fott-ABS approved head to maintain vessel operation.
- 3. f4 ries the season, the starboard main engine vibration damper was observed
William Hudson / Director February 2, 1979 SUBJ: M/V COLUMBIA Main Propulsion Engines Cont'd Page Il not rotating af ter engine start-up upon completion of fueling in Seattle. Subsequent investigation revealed that the drive coupling between the damper and tne engine crankshaft had loosened and scored the end of the crankshaf t and mating coupling. This inspite of the fact that the retain-er bolts were intact and locked in place by a lock plate. The bol ts them-selves wer.e found hand tight or below torque limits. Temporary repairs were made with ABS and CG approval and the vessel was able to remain in service with the provision that permanent repairs be effected during the forth-coming annual repair period. E. The oil filter problem became worse as the season progressed. Continual engine oil analysis revealed heavy carbon and soot deposits as well as water in the engine lube oil in both the part and starboard main engines. The starboard engine was the worst. The water presumably entered the lub-ricating system via cracked or defective cylinder heads. The particular. leaking heads could not always be located since water was not evident dur-ing engine blow down. Soot deposits and buildup was clearly evident on the top deck of the majority of the cylinder heads indicating that exhaust gases were blowing up past the valve assemblies into the rocker box area. Most of this soot and carbon was being washed down into the engine via the lubricating oil flowing out of the rocker arm assemblies, and was the source of at least a aortion of our oil filter plugging problem. Loss of engine crankcase vacuum observed by tow (2) different crew members on two (2) separate occasions suggested blowby past the pistons. This situation was not totally unexpected based on the liner scoring observed during several base inspections made during the season and the probability that upper piston ring chrome failures were occurring on several pistons as had been observed on the #7 cylinder, outboard, starboard engine, just prior to starting the seasons runs. It was quite probable that this blowby was also contributing to the oil filter plugging problem. F. In spite of almost continual operation of the lube oil purifier, the lube oil filter life kept dropping, necessitating frequent change outs. This condition had been getting progressively worse during the past two (2) seasons and of which DeLaval was made well aware. The purifier could be operated only two (2) hours between shots due to excessive buildup of
. sludge in the bowl.
G. During the last two (2) months of vessel operation, filter change intervals had dropped to less than thirty (30)^ hours and had necessitated the use of approximately 600 filter elements at a cost in excess of $5,500.00, ex-clusive of lube oil and man / hours. Af ter completely hanging out lube oil in the starboard main engin'e, in one instance, and installing new filter elements, the filters lasted only a total of 52 hours. H. Because of an inability to shift filter cases while underway, the engine had to be secured each time the filter's were shifted. This condition has existed since vessel delivery, but was considered a low priority corrective
William Hudsr'n/ Director February 2, 1979 SUCJ: N/V COLUMBIA Main propulsion Engines Con t' d Page III item until recently because of the magnitude of other engine problems. With sustained engine operation based on lobe oil filter life, the vessel had to increasingly stop prior to entry'into restricted or hazardous - waters to shif t and change fil ters. In one instance, the starboard engine had to be shut down while transiting a narrows to permit shifting of the fil ters. At that time the vessel was heading into a strong tidal current. Tne necessity to secure the engine placed the vessel in a hazard-ous condition and had it not been for the expertise of our M/V COLUMBIA crew, the results could have been disastrcus. I. DeLaval's action with respect to these problems was for the most part not-responsive, although they did have a representative meet the vessel in Seattle, almost weekly. We did change out all fuel injector spray tips, during the season, from 150 to 1400 as per DeLaval's recommendation and a t owner's expense. This obviously was an attempt to reduce carbon build-up within the combustion chamber and eliminate washing of the liner walls with fuel oil. DeLaval finally became somewhat interested as a result of a newspaper article (see enclosure (1) which appeared in the Seattle, P.I., on September 1,1978, and relating to the States decision to pull M/V COLUMBIA out of service early because of propulsion engine difficulties. DeLaval responded by letter dated October 31, 1978, copy attached as en-closure (2). J. Because of the inference in their letter that the State exercised poor judgement in the decision, we replied by my letter of November 8,1973 attached as enclosure (3). K. At that point, DeLaval's interest appeared to gaih momentum. A meeting was held in Seattle, on November 14, 1978, between Marine Highway System and DeLaval personnel. We had already begun the third major overhaul of both main engines in five (5) years with only a total of approximately 17,090/ hours on the P.M.E. and 16,699/ hours on the S.M.E. Based on hours alone, for a normal engine of comparable size, we should have been approach-ing our first major overhaul period. During this meeting, we again pointed out the existing engine problems and noted many new problons discovered during the engine tear-down up to that time. ' L. The existing problems covered were basically the cylinder heads leaking water, carbon accumulations in the rocker box areas, excessive oil vapor discharge from the engine crankcases, fire ring failures, contaminated engine lobe oil, short lube oil filter life wherein the filters were dic- , tating vessel operations rather than the operator, the discovery of metal j particals attached to the main engine lube oil suction strainers magnates, i and 1iner scoring. l M. The new items uncovered during engine tear down and discussed at the same meeting included the following; '
William Hudson / Director February 20 1979 SUBJ: M/V COLUM31A Main Propulsion Engines Cont'd Page IV
- 1. Heavy carbon deposits collected within the valve spring assem-blies.
- 2. Discovery that when the exhaust valve 9 aides were modified by DeLaval two (2) years ago, because of 3rather problem, they did not follow the procedure specified in their SIM (Service Infer-mation Memo). .Instead of machining off the portion of the ex-haust valve guide extending down into the exhaust port flush with the casting, they'had in most cases counterbored the cast-ings as deep as k" past the c.asting face'. This action apparent-ly destroyed the exhaust gas flow and was contributory to the soot build-up in the rocker box areas. It should be noted that the sooting problem in the rocker box areas was less of a prob-lem prior to the guides being modified by DeLaval.
- 3. Intake valve stem wear in way of the oil seals added by DeLaval two (2) years ago. This was an attemp to stop the lube oil thought to be flowing from the rocker box area into the com-bustion chamber and causing excessive carbon build-up on the valves and combustion areas.
4 Chrome flaking off of the valve stems themselves.
- 5. Chrome failures on the upper piston rings causing both piston and liner scoring. Two (2) liners were found worn beyond limit:
- 6. Taper piston rings excessively worn.
- 7. Loose piston pin end caps
- 8. Incorrect piston crown to skirt bolt torque valves
- 9. Unsatisfactory condition of rod bearings
- 10. Discovery of five (5) damaged rod bolts
- 11. Variations between cylinder heads as to whether they had buf-fer springs, valve rotators, etc. , or not.
- 12. Piston blowby.
- 13. Damaged fire rings.
N. A second meeting was held on November 21, 1978, in Seattle, between Marine Highway System and DeLaval personnel during which time DeLaval was to pro-vide answer to the problems noted in the meeting the week before. What followed was a profusion of recommended changes and modifications, the cost presumably to be born by the Owner along with the Owner making the decision as to whether the changes or modifications were infact to be done. These changes or modifications included the following;
- 1. Change turbocharger nozzle ring areas. This was not agreeable to the State and DeLaval cc curred that it was not a desirable change, at least at this time.
- 2. Retard the exhaust cam timing by 10 crankshaf t degrees. This was incorrect since tne exhaust cams should be advance 10 crank-shaft degrees, not retarded, for the purpose DeLaval intended.
This suggested procedure was changed by DeLaval accordingly. This has now been accomplished by the Owner. i
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willfam. Hudson / Director Fecruary 2,1979 stBJ: M/V COLif'S:A Main Propulsion Engines Cont'd Page V
- 3. Make piping changes to the lube oil filter change-over valve to permit shifting of the filters without shuting down the effected engine. This will be accomplished by the Owner.
- 4. Machine hone all cylinder liners to assure proper liner finish.
Since there was disagreement in the past as to what constituted a proper liner finish, 30 of 32 cylinder liners were sent to DeLaval for factory rework. The remaining two (2) liners were beyond further use and new replacement ordered. Unfortunately, these two (2) new 1iners, plus at least one of the two procured at the beginning of the season were received with the incorrect liner finish requiring return to DeLaval for exchange.
- 5. Recomnendation that all pistons be modified in accordance with procedures that were being promulgated but was not yet available.
When received, the nodifications were found to be extensive and critical to the point that no local firms would take on the re-sponsibility of the job. Hence, all 32 pistons were sent to Oakland, California, for modification and installation of re-quired new components. The required modifications clearly revealed that because of design problems, lube oil was actually permitted to escape from the piston, above the oil control rings, and was entering the comoustion area. It is our opinion that this situation contributed to the major portion of problems from the on-set with respect to carbon build-up on the valves and contaminated lube oil. The mods additionally closed up a portion of the oil control ring drain holes because they were not functioning as designed and infact operated in reverse of the original intent. Copies of DeLaval letters of November 17, 28, 1978, relating to suggested engine modifications, as noted above, are attached as enclosure (4) and (5). These piston modifications will result in a relatively dry liner and piston assembly, the result of which can only be proved in time in our appl ica tion. O. In conjunction with the main engine overhaul, the following work has thus far been accomplished or is programmed;
- 1. All four (4) main engine turbochargers were pulled for inspec .
tion. Deposit buildup on the turbine blading was again evident but less than in prior years. The rotors were sent out for cleaning to establish a base point for future comparison. A hot side bearing and a set of new seals were renewed in one unit because they had allowed the shaft to drep to the point that the lambrith seal was starting to rub. The bearing itself was just short of reaching the maximum wear limit.
- 2. All 32 cylinder heads were removed, hot dip cleaned, pressure tested, ' checked for cracks and fire deck warpage. Seven (7) of the cylinder heads revealed cracked exhaust valse seats, one (1) . ,
head had a water leak in the intake valve port casting and three (3) heads nad eter leaks in the exhaust valve port casting. Eleven (11) cylinder heads in total vare sent to DeLaval for re-l l l
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William Hudson / Director Feb uary 20 1979 Sd3J: M/V COLUMSfA Main Propulsion Engines Cont'd Page VI pair and return including two (2) which were typical in-so-fa as warped fire decks. DO_aval was also requested to relieve the counterbore, a t their expense, that they created when the exhaust valve guide were cut back two (2) years ago. See iter M-2. We had the counterbores dressed upon the remaining 21 cylinder heads locally. The cylinder heads were returned by DeLaval without relieving of the counterbore. Because of time limitations, we were only able to locally relieve four (4) more of the returned heads. The remainder will have to be mod-in the future. Several additional heads were sent to DeLaval because the valve seat material remaining was insufficient to permit proper valve seat grinding and valve lapping in. This resulted from the necessity in the past to excessively grind in the valve seats because of misaligrnent of the valve guides to the seats, a quality control problem. It should be noted that the new seats on several of the repaired and returned heads were again found not concentric with the respective valve guides and excessive grinding was again required. One repaired head was so bad it is being returned to DeLaval for corrective action. Buffer springs were installed on all heads not previously so equipped. This required the use of differ-ent valve spring retainers, which we attempte,d to order. De-Laval, advised that we did not need different retainers since the original ones would fit. This. again revealed that DeLaval does not understand their engine. We modified all existing retainers using a local shop and sent DeLaval a sketch of the changes required. DeLaval must have gone through this before since what few cylinder heads we had with buffer springs in-stalled, also had the correct spring retainers. DeLaval did furnisn one (1) modified head that reportedly has been strength-ened at the 3 and 9 o' clock positions. If successful, this action is intended ta compensate for the irregular head bolting arrangement which has pernitted the original heads to warp anc/ or cause the prematu're fire ring failures. Inspection of this head, prior to installation, revealed that the location of the studs for the air start valves had been changed. Inspection of exhaust and intakes showed that the valves had not been proper-ly seated bf DeLaval. The situation was cor~rected by the crew with additional grinding and lapping, requiring many hour of labor. Again an indication of poor quality control by DeLaval .
- 3. Permanent repairs have been effected to the starboard engine vibration damper crive hub and engine crankshaf t. This, how-ever, required dismantling of the major portion of the star-board main engine front end.
- 4. The port main engine vibration damper drive assembly was in-spected and the drive hub retaining bolts found not up to proper torque. Considerable fretting was noted on both the shaft and and the hub.
William Mudson/ Director February 2,1979 SUBJ: M/V COLUPSIA Main Propulsion Engines Con ti ' d Page VII
- 5. There is concern about the dif ficulties experienced to cate with the vibration da.nper assembly, especially due to the possibility of a crankshaft failure. The location of the damper assecbly pedestal bearing on the tank top is presumed to be the most probable cause of the coupling failure. This installation was however, approved by DeLaval.
- 6. Front end gear train backlash reading were taken. The timing gear on the starboard main engine was fcund to have galling on the teeth and dye checki.ng revealed the existance of cracks at or near the pitch line. It appeared as though the gear had never been fully finished during manufacture and it did not run true with mating gears as if cocked. Inspite of the con-dition of the timing gear, DeLaval advised there was nothing wrong wi th it. We could not accept this statement based on our observations. Ordered new timing gear was not identical to the one removed, suggesting possibly a design change in manufacture.
- 7. Found four (4) valve push rods cracked at the point of weld-ment of the pipe to the ball joint. Clearly a quality con-trol problem. Ordered replacements from DeLaval
- 8. Renewed all valves which had chrome failure on the valve stems.
- 9. Renewed all intake valves which had excessive wear on the stems due to the previously installed oil seals.
, 10. Rerolled all loose piston pin end caps. (At least 507, were found loose).
- 11. Procured and installed new type piston ring sets. Some of the new sets receivec were defective and had to be returned to DeLaval for exchange. '
- 12. Installed valve rotators on all exhaust valves where found not previously installed.
- 13. Inspection of the rod bearings by the DeLaval representative, during engine tear down, in October,1978, revealed several shells to be at or below the low limit. Dirty oil, resulting from the carbon and soot entering the engine had effect on this.
Several shells showed signs of fretting, 'had indications of cracks and showed loss of bearing plating material. We were concerned about the overall condition of the bearing shells but were advised by DeLaval personnel in Oakland, that the situa-tion-was normal and not a problem. The DeLaval representative recommended that only two (2) bearing halves need be replaced and the remainder reinstalled. However, as the crew was pre-paring to reinstall the bearing shells some time later, a dif-ferent DeLaval representative, whom had been hired at owner's ' expense to supervise and/or witness tne overhaul and engine reassembly, suggested otherwise in mid January,1979, three (3) months after we had been advised that we should not be reinstall-ed and that new shalls of improved type should instead be pro-cured and installed. Two (2) engine sets were imediately
Billiam Hudson / Director February 2,1979 SUBJ: M/V COLUMBIA Main Propulsion Engines Cont'd Page VII-ordered from DeLaval for air shipment to the vessel in order
.to minimize reassembly delays. Inspection of the new bear-ing shells revealed they were for a 13" crankshaft bearing
.and not for our 12" crankshaft bearings. We strongly suspect.
that a major change has been made by DeLaval with regard to new crankshafts. For what reason we can only speculate at this time. DeLaval was notified of the error in bearing shells supplied (one of many part supply errors experienced thus far) and we were informed that only 20 bearing shells of the type required were available. The remainder would have to be manufactured. As of January 29, 1979, we had received only 10 bearing halves and are awaiting the remainder. Sev-eral days delay in engine reassembly _ have thus far occurred as a result of the connecting rod bearing problems.
- 14. Inspection of the main bearings revealed that the lower shell halves were at maximum wear limits. The bearings were rotated to place the upper. halves on the bottom. The wear rate of the main bearing shells appears excessive for a normal engine of this size and rating, and was no doubt effected in part by the dirty oil . By rotating the bearing halves, they shouiJ provide another 17,000/ hours of operation af ter which time all main bearing halves will require renewal. It should be noted that the hydraulic boit strecher, a special tool ordered from DeLaval for use in checking main bearings, could not be used on the forward two (2) nuts on the front bearing cap. This because of interference with the idler gear bracket. Required two (2) days of grinding on the brackets to clear.
- 15. During shifting of the exhaust cams, as indicated in paragraph N-2, it was found that the hard facing on the fuel pump cam noses had been worn through. This was another unexpected sur-prise. Since the cam is wider than the follower, the cams were slipped sideways to permit the follower to contact, for the rost part, the remaining good face on the cam nose. It will be necessary that the fuel cams be changed out next year. Addi tion-ally, the other cams indicated excessive hard face wear and will presumably also require renewal next year.
-16. During removal of the main engine turbocharger for inspection, one (T) of the flexible, outlet ducts was found cracked and a replacement was ordered. The new duct furnished did not match the original and was too short. The matter was discussed with DeLaval who stated that it was a new design an.d it would not huri. for us to expand it approximately one inch over what the pre-assembly lock bars permitted. We disagreed with their comments and DeLaval agreed to provide a letter covering the subject. The. unit was placed into position to prove our point and when the flange faces were pulled up tight, the flex con-( volutions were 'touching at the bottom and expanded to near break-ing at the top. This because the flange faces are not parallel on this or any of the other three (3) identical installations.
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William Hudson / Director February 2,1979 , SUBJ: M/V COLUMBIA Main Propulsion Engines Cont'd Page IX The unit.has now been permanently distorted and will be re- !
. turned to DeLaval for their inspection and disposition, with a request that the proper flex joint be furnished ASAP.
- 17. During the past season, two (2) different centrifugal fan units were provided by DeLaval and installed by the owner,-in hopes of stopping the excessive oily vapor discharge into the stack space, which is an extreme fire hazard. This condition has persisted since vessel delivery and DeLaval has been continu-ously pressured for corrective action. Both units failed to -
alleviate the problem. Electronic precipitator have been procured by the owner for installation prior to vessel's return to service, in hopes of finally resolving the oil vapor problem. P. It is interesting to note that during this entire engine overhaul period, covering four (4) months todate, no one from DeLaval Management, Eng-ineering, Customer Service, or Field Service, has visited the vessel. This excludes the field representative furnished by DeLaval during ini-tial engine tear down and the field representative we cont. acted for to witness engine reassembly. Tnis suggest a total lack of interest by DeLaval in our existing long tem problems, new problems found during tear down, recent problems relating to part support, lack of quality control with respect to parts and shop-work performed by DeLaval . The situation is unbelievable considering the fact that we have repeat-edly expressed concern and dis-satisfaction with the performance of COLUMBIA'S main engines to DeLaval. DeLaval expressed more concern over the PI news article than they have to this long and expensive over-haul and modification project. , Q. The crew labor, part procurement and outside service costs, associated with this main engine overhaul, will be tremendous when finally conclu-ded and tabulated. This situation is not unlike that experienced in prior years. We still. have no assurance that the DeLaval engines are any more reliable now or can provide any better sustained operation than when first installed. All indications are that the COLUM3IA'S main engines are still in the design stage and are in effect being field engineered by DeLaval at the owner's expense. One can always expect some problems with a new installation. These are normally cleared up in the first couple of years. In this case, the problems have existed for five (5) years with no end in sight. Only two (2) significant changes have occurred during that time. The new exhaust manifolds and the 'urbocharger mods, both of which hav'e thus far proved sa tis factory. Based on past history and inspite of all the changeouts and modifications made this overhaul period, I would estimate that we can only plan on this and possibly one more season of operation before we will be forced to go
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. William Hudson / Director . February 2, 1979 SUBJ: f t/V C0l UMBIA Main Propulsion Engines Cont'd .Page X through a similar exercise. This of course assumes wa experience no nea major break-downs or failures in the interim.
At this point we have two options. One (1) is to continue operating M/V COLUMBIA as before and hope that in' time we will end up with re-liable operating main propulsion engines. Under this option, DeLaval must be made to assume a greater share of the overall responsibility and associated costs. They in fact snould assume responsibility for a portion, at least, of our current engine overhaul and modification costs. The other option is to immediately start on a program to re-engine M/V COLUMBIA. We hopefully have two (2) seasons during which time the design, engine selection, procurement and delivery can be effected. I would not venture in this direction unless DeLaval refuses to accept a greater share of the overall responsibility and cost in resolving the engine problens. Because of the time frame, it is important that a meeting with Mr. Martini be scheduled as soon as practicable to ascertain their future participation. Just what legal recoursewe have in this matter is unknown to me. I will meet with Attorney Davidson, af ter he has had time to digest this publication and solicit recommendations. Sincerely,
,- h L/.,4 b Max Zbinden Proi ct Engineer Alaska Marine Highway Pier 48 Seattle, Washington 98104 MEZ:abh
Enclosures:
(1) Seattle P. I. new artitie (2) DeLaval letter of 31 Oct. 1978 (3) Alaska letter of 08 Nov.1978 (4) DeLaval letter of 17 Nov.1978 (5) DeLaval letter of 28 Nov.1978 cc: R.Wa rd/ Commi s s ioner M.Griggs/ Administrative Officer Dav idson/ Attorney H. Mcdonald / Port Engineer M/V COLL'MBIA/ Chief Engineer
4 Wf ! Y f '$ ? !. .' Q !% f.l? hlbY$hlu 50 $IJ a * * "** mm DEPAR ra!EN T OF TR \b5 PORT \ TION AND PUP,LIC F ACILITIES WAlNTEtWCE AND CPERATIC .S DI VISION OF &*A RINE HIGhWA Y SYSTEAG- l March 19, 1979 DeLaval Engine & Compressor Division 550 - 85th Avenue P.O. Box 2161 Gakland, California 94641 SUBJ: M/V COLUMBIA'- Main propulsion engines ATTN: Mr. Douglas Martini
Dear Mr. Martini:
During the 1978 season, M/V COLUMBIA experienced the continuation of cylinder head and fire ring problems. These problems introduced water into the engine lube oil systems and combustion gases into the cooling water system. Frequent fire ring renewals and cylinder head removals and/or renewals were required. We also experienced the starboard main engine crankshaft to vibration damper coupling failure and were able to make temporary repairs. The previously reported accumulations of carbon / soot in the, rocker box areas be-came increasinoly worse. The dirty lube oil problem, experienced during the prior two seasons, continued and became steadily worse. With lube oil filter change intervals down to as low as 26/ hours, which seriously effected the safe and prudent operation of the
, vessel, M/V COLUMBIA was removed from service in September,1978.
We immediately started on a program to remove and thoroughly inspect all cylinder heads to detennine which heads were leaking water, in-spect. the condition of the valve guides and valves and related clearances, renew fire rings as necessary, pull and inspect selected-rod and main bearings for required ABS inspection, effect more per-manent repairs to the S.M.E. vibration damper drive coupling 'assem-bly, check the P.M.E. vibration damper drive coupling assembly, in-spect the condition of the turbochargers after accumulating approx-inately 3000/ hours of operation, and inspect several pistons wherein the associated liners were becoming increasingly scored, possibly due to piston ring failures and carbon accumulations. At our meeting in Seattle, on November 14, 1978, we discussed the continuing engine problems. We specifically noted the cylinder head y ,,n-
DeLaval Engine & Compressor Division March 19, 1979 SUBJ: M/V COLUMBIA - Main propulsion engines Page II-(Cont'd) ATTN: Mr. Douglas-Martini problems, carbon accumulations in' the rocker box areas, excessive oil -vapor discharge from the engine crankcase, fire ring failures, contaminated engine lube oil, short oil filter life, inability to shift M.E. lube oil filters while underway, finding of metal part-icles in the engine lube oil suction strainer and continued liner scoring. Resolution of these problems.was long overdue. New problem areas and the effects of many existing ones, uncovered during engine tear down up to that time, were also discussed at the same meeting. These included the following:
- 1. Heavy carbon deposits collecting within the valve spring assemblies.
- 2. Discovery that in machining of the exhaust valve guides two (2) years ago, DeLaval created counterbores in the cylinder head exhcust passages. Corrective action was deemed necessary since inspection revealed that the de-gree of counterbore had an effect on the exhaust gas flow and was directly related to the amount of soot noted in the rocker box areas.
- 3. Heavy intake valve stem wear in way of the oil seals add-ed by DeLaval two (2) years ago. Would require renewal of a number of valves and seals.
- 4. Chrome failure on both intake and exhaust valve stems due to an apparent QC problem. Would require additional valve renewaTs.
- 5. Chrome failures on the upper piston rings causing both liner and piston scoring and excessive wear of the taper piston rings. Assumed a design or QC problem which would require inspection of all pistons, honing of all liners and installation of new piston rings throughout.
- 6. Approximately 50% of the piston end caps were found loose.
- 7. Piston crown to skirt bolt torque valves were found in-correct.
- 8. Unsatisfactory condition of all rod bearing halves.
- 9. Discovery of five (5) damaged rod bolts.
- 10. Discovery of four (4) cracked push rods.
- 11. Variations in cylinder head assemblies as to whether equipped with buffer springs, valve rotators, etc. , or not.
- 12. Piston blow-by.
- 13. Camaged fire rings.
At our second meeting in Seattle on November 21',' 1978, DeLaval offer-ed several suggestions toward resolving some of the engine problems. These included the following:
- 1. Change turbocharger nozzle ring area, i
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r: DeLaval Engine & Compressor Division March 19, 1979 SUBJ: M/V COLUMBIA - Main propulsion engines Page III-(Cont'd) ATTH: Mr. Douglas Martini
- 2. Advance exhaust cams by ten (10) crankshaf t degrees.
- 3. Make piping mods to pennit shif ting main engine lube filters while underway.
l 4. Machine hone all cylinder liners.
- 5. Modify all pistons which would require machining, part changeouts and use of new type / style piston ring sets.
f l With the exception of item 1, all of the suggested modifications were incorporated into our already expanded engine inspection and overhaul program, necessitated by a variety of other reasons. Among these were the results of rod and main bearing inspections which re-flected excessive wear and bearing shell failures and required in-i spection of all the bearings. finding of a damaged and cracked i timing gear on the S.M.E. Improper S.M.E. gear train alignment. Finding of fretting in the 'P.M.E. vibration damper drive hub. Dis-covery of continuing cylinder head defects such as warped fire decks, cracked valve seats, casting pin holes into water passages. Loss of hard facing on the fuel cams and evidence that a similar condition was starting to occur on other cams. The entire engine overhaul program required approximately five (5) months and constituted the third major overhaul in five -(5) years of operation. Delays were encountered in part shipments and deliveries of incorrect or defective parts. In shop repairs of cylinder heads resulted in receipt of many heads with rebuilt valve seats badly out of round and not concentric'with the valve guides. This required extra man / hours of labor to resolve and required the removal of much of the seat hard facing material. @ is has been a long term problem and greatly shortens the life of the valve seats. Additionally, our request for the DeLaval shop to remove the exhaust port counterbores on those cylinder heads returned for rework was ignored. The State corrected the condition on all but four (4) heads which were not received in time to correct prior to installation. During this past overhaul period, we accomplished the following:
- 1. Pulled, cleaned and reinstalled all four (4) turbochargers
. to establish a base point as to future operation. Addi-I tionall'y, changed out a hot side bearing and seals due to l excessive wear.
- 2. Pulled, cleaned, tested and repaired as necessary and re-installed all 32 cylinder heads. This included the re-l newal of many valves and seats for reasons previously
( noted, installation of buffer springs and valve rotators where found missing and new fire rings. Removed exhaust port counterbores in all but four (4) cylinder heads l which were not received in time to so modify. Add i tion-ally, expended many un-necessary man / hours to correct concentricity problems between valve seats and guides,
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DeLaval Engine A Compressor Division March 19, 1979 SUBJ: M/V COLUMBIA - Main propulsion engines Page IV-(Cont'd)- ATTN: Mr. ' Douglas- Martini which for the most part removed the greater portion of the valve seat hard metal facing again.
- 3. Pulled all 32 cyl,inder liners for inspection. Thirty liners were snipped to DeLaval 'for shop machine honing.
Two (2) liners were renewed due to excessive wear bring-Ing the total number of liners renewed to date to five (5) of which only one (1) could be reclaimed. Re-machined one (1) P.M.E. liner landing in the block to p" ovide flat seating surface. Reinstalled 32 liners using new liner seals.
- 4. Pulled all 32 pistons for inspection and subsequent ship-ment to DeLaval for modification. Reinstalled same using new style piston ring sets. Rerolled all piston pin end caps. Have reservations on long tenn effect of the dry
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liner and piston configuration resulting from the piston mods in marine service such as ours.
- 5. Renewed all connccting rod bearings.
- 6. Reversed all main bearing shells because of excessive wear and plating failure on the lower (load) halves.
- 7. Renewed the S.M.E. timing gear and realigned the gear train.
- 8. Reset all exhaust cam and renewed four cracked push rods.
- 9. Shif ted fuel cams because of hard facing wearn
- 10. Inspected and dye-checked all rod assemblies and renew-ed five (5) damaged rod bolts.
- 11. Effected repairs to Port and Starboard M.E. vibration
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damper drive coupling assemblies. (Have reservations on use of N.C. threads on 1 1/8" locking plate cap screws - and the location of the damper pedestal, bearing on the tank top in lieu of being tied into the engine foundation structure).
- 12. Renewed S.M.E. cracked turbocharger outlet flexible section.
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- 13. Installed electronic precipitator units in the crankcase blower ventilation piping to eleminate oily vapor dis-charge into the stack space.
14 Modified lube oil filter piping to permit change over while engines are operating. (Reportedly still difficult)
- 15. Changed out all lube filters prior to and again after sea trials.
- 16. Cleaned crankcase and bases and filled engines with new Shell Rotella T-40 lube oil.
- 17. Installed one (1) modified head on the P.M.E. for evalu-ation of reinforced side sections.
- 18. Checked out and set engine timing.
- 19. Reset rack transmitters and set blade pitch at zero.
- 20. Changed out one main engine governor.
DeLaval Engine & Compressor Division March 19, 1979 SUBJ: M/V COLUMBIA - Main propulsion engines Page V---( Cont'd) ATTN: Mr. Douglas Martini It is dif ficult to . comprehend the total ef fort and monies expended during the past five (5) years in association with the M/V COLUMBIA main engines. This with only 16,699/ hours accumulated on the S.M.E. and 17,090/ hours on the P.M.E. During this same five (5) year per-iod, only two (2) significant changes or improvements have been developed. The new exhaust manifolds and the turbocharger modifi-cations, both of which have thus far proved satisfactory. The re-cent piston modifications may resolve the long term problem with respect to engine oil contamination and related side effects. This remains to be proved in service. However, many other problens re-main. .These include such items as cracking of cylinder heads, cracking of valve seats, warpage of cylinder heads, burning out of fire rings, etc. We also have material or QC problems with respect to non-concentricity of valve guides to valve seats, push rods, rod bolts, bearing shells, valve stem plating, hard facing on cam lobes, etc. Nothing has been accomplished to date to resolve these areas. At this point, the State of Alaska is faced with two (2) courses of action. One (1) is to take advantage of the fact that both main engines have just been overhauled and should provide at least one seasons satisfactory operation, discounting the continued head and fire ring problems. During this period of time the State could start on a program to re-engine the vessel to provide a more reli-able and less costly propulsion system as far as maintenance and labor dollars are involved. This action would necessitate imedi-ate action due to the time frame involved. The other course of action would be to continue as we have in the past and hope that in a reasonable amount of additional time we would end up with reliable operating main engines, derated in effect, and whose maintenance ef forts the State could afford. Under this course of action, DeLaval must assume a greater share of the overall responsibility and associ-ated costs toward final resolution of the existing problems. DeLaval should assume responsibility for at least a portion of our recent overhaul / modification costs. Because of the time frame, a meeting between you and I should be scheduled as soon as practicable to as-certain DeLaval's- future participation in. this project. We should also discuss recent part support problems, ap. parent quality control problems, unsatisfactory shop work, etc. Your earliest reply would be appreciated. Sincerelytl-
~
i . w?.e Max E. Zbinden MEZ:abh Project. Engineer CC: (Cont'd) t e, Washington 98104-
DeLaval Engine & Conipressor Division March 19, 1979 SUBJ: M/V COLUMBIA - Main propulsion engines Page VI--(Cont'd) ATTft: Mr. Douglas Martini CC: Robert Ward / Commissioner Merv Griggs/ Administrative Officer Davidson/ Attorney A.H. Mcdonald / Port Engineer M/V COLUMBIA / Chief Engineer e e S
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, j (3 l W 5 MMCMO. CCVERMC2 Di PA:t FM'dNT OF TR ANSPORTATION AND PUBLIC FACILITIES MAINTENAACE AND GPERATIOf.S CIVISIONOFMARINEHIGMVAYSYSTEh6 June'l4, 1979 Transamerica DeLaval, Inc. ,
Engine and Compressor Div. ' , 550 - 85th Avenue Oakland, California 94621 SUBJ: M/V COLUMBIA; Main Propulsion Engine ( ATTN: Mr. Douglas Martini
Dear Mr. Martini:
l I am sure that most of us came away from the ' meeting in Seattle, on June 12, 1979, feeling that little had been resolved. The reintro-duction of our letter of March 19, 1979, was not intended to rub salt into any wound. It was brought out since it was the basis' of our request for such a meeting and covered the spectrum of our M/V COLUM-BIA main engine problems. You must appreciate our concern over the long term design and/or QC problems effecting the engines. Hopefully, the recent piston modifi-cations will prove to be a step in the right direction. The modified cylinder head presently being evaluated may also prove successful. In any case, resolution of the problems must come from the engine manufacturer. The problems experienced to-date have resulted in totally abnormal and excessive maintenance efforts regarding M/V COLUMBIA. These in-clude excessive down time for repair and overhaul with resultant l revenue loss, excessive expenditure of maintenance man / hours and the l continual premature' repair and/or part replacement costs, particularily in view of the low total operating hours to-date. l l It would be to the advantage of both the State of Alaska and DeLaval ! to make the installed propulsion engines function properly., Reliabil- ! ity and total operating costs are prime considerations. To this end DeLaval must assume a greater share of the overall responsibility and l associated costs toward satisfactory resolution of the problems. l As discussed at the meeting, we shall continue operation of the one l modified cylinder head, presently installed on the port main engine,
,e _ _ _ _ - , , , _ , , . ~ - -
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Transamerica DeLaval, Inc. June 14, 1979 Engina and Compressor Div. Page II 550 - 85th_ Avenue Oakland, California 9461 SUBJ: M/V COLUNIA; Main Propulsion Engine--(Cont'd) ATTN: Mr. Douglas Martini until you direct otherwise. We are awaiting your rccommendations for modification of the exhaust manifolds to resolve the thermal growth and cracking problems. Since the State excepted the manifolds as a final fix for previous manifold problems, the cost of such modifica-tions will be the States responsibility. You will be advised in the near future as to our tentative plans regarding repair of the engine camshafts. Additionally, the J-26 cylinder head with a crack in the port area just above a renewed valve seat will be returned to your facility for repair and return. Per your request, copies of several paid and unpaid invoices are en-closed for your review and action. These invoices for the most part cover parts and shop work required as a result of what we believe to be design and/or QC problems. These are not considered product im-provements, such as the fuel injector tip change out, wherein the owner had the option to make the change or not, depending upon his de-sire to improve fuel consumption, etc. These are also-not considered to be normal maintenance costs in view of the relatively low opvating hours of the engines. The unpaid invoices total in excess of $120,000 and the paid invoices are .in excess of $31,000. The above invoices concern only M/V COLUMBIA. They do not include in excess of $20,000 paid for DeLaval Technical Representative service during the overhaul, although this point could be argued. Nor do they' include approximately $43,000.00 additional costs to the State for outside jobbers to re-lieve the cylinder head exhaust ports, effect SME crankshaft repairs, procure and install electronic prec,ipitators on the crankcase vents, installation and renoval of DeLaval furnished American Air Filter centri-fugal oil separators on the same vents which proved ineffective in our application, modify existing valve spring retainers, grind valves, ma-chining of a liner landing area on the PME block, etc., although at least a portion of this work was necessitated due to premature need for engine overhaul or poor QC. The remaining M/V COLUMBIA ' invoices, which basi-cally cover expected and nonnal replacement items, have been or are being processed for payment to DeLaval. Your comments are desired. Rest assured that the State will assist in anyway practicable toward resolution of the problems, if sc"le mutually agreeable policy and course of action can be established.
<fSincerely.,' f MEZ:abh
/ Pro ec E gr CC: Robert Ward / Commissioner.w/o encl.,/ //V Jim Eide/ Director-w/o encl .
Davidson/ Attorney-w/o encl . Merv Griggs/ Administrative Officer-w/o encl. A.H. Mcdonald / Port Enoineer-w/o enc 1. 1 J
e IT3BSamETMS $ $n C. *c*o $ ,'e',*7 *s.,,,on .
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g) 550 85m Avenue P CL Box 2161 Oakland. Calefomia 94621 (415) 577-7400 June 21, 1979
; State of Alaska Department of Transportation & Public Facilities Division of Marine Highway Systems Pier 48 Seattle, Washington 98104 Attn: Mr. Max Zbinden
Dear Mr. Zbinden:
As a result of our meeting last week, I believe we have a better understanding of how Alaska Marine Highway looks at Transamerica q Delaval. Your letters have outlined in general year thoughts and 1 we offer the following in response:
- 1) By this time Alaska Marine Highway should full'y realize that Transamerica Delaval has met all of its obligations, both moral and contractual.
- 2) The past agreement made between Alaska Marine Highway and Lock-
- head has been fulfilled by both parties within the times allotted.
- 3) We don't understand the continuous threats of legal confrontation.
(Notice copies of all' letters to Alaska Marine Highway attorney's)
- 4) We at Transamerica Delaval always endeavor to promote excellent relations _with our customers. In order to continue this policy, and to evidence good faith we would like to discount the total i of the parts invoices not paid to date of $123,809.88 by 35' for
.i a net of $80,476.42 without further obligation except to assist where you belle 0e Alaska Marine Highway has needs. A credit memo is attached hereto in the amount of $43,333.46. 1 The above is offered as a gesturs of goodwill and will be charged to Sales Policy. The of fer is not intended to imply responsibility on the part of Transamerica Delaval for the expense, or success of the overhaul work. It is expected that Alaska Marine Highway will ful-fill their obligations and promptly make payment in the amounts out-lined above as well as other past due invoices.
. Transemanca ^ Dalaval 1.,4.?. j i.... L Alaska Marine Highway June 21, 1979 , Page 2 We.want to thank you for the meeting and hope that we can work together in the future. l Sinderely,
* ' :) f .
j i km W D. H. Martini j- Vice President & General Manager DICi:pt i Attachment . cc: T. Eiden a I t l-4 4 e i 1 i i 4 4 4
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- o We hereby certefy that these goods wnre produced in cornphance weh all appiscoble requerernents of Sections 6. F. and 12 of the Fair Labor Standards Act, as asnended, and at requisesons and orders of tne Uneted $ sales Departsnent os Laeor issued unde Section la thor.+of.
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DT L IUGONO. GOVERMCI lit:P A RTM ENT OF TR ANSPORTATION AND PUBLIC FACILITIES
?.WNTENAACE AND CPERATIOfS DIVISION OFStARINE HIGHM YSYSTE*2 July 10, 1979 Transamerica DeLaval Inc.
Engine & Compressor Division 550-85th Avenue Oakland, California 94621 SUBJ: M/V COLUMBIA Main Propulsion Engines ATTN: Mr. Douglas Martini
Dear Mr. Martini:
The proposal contained in your letter of June 21, 1979, relates to unpaid part invoices in the amount of $123,809.88 wherein, the total of unpaid invoices in question amounted to $126,607.62 and included shop as well as part costs. Furthermore, it did not address the $31,170.75 ~of paid invoices in question nor credits against invoices totaling $22,369.34, for incorrect parts which were returned to your facility. The State of Alaska, intends to meet its obligations with respect to the services and parts furnished by Transamerica DeLaval during the past over-haul of the M/V COLUMBIA'S main propulsion engines. We do however, belicve that Transamerica DeLaval, has some responsibility for a portion of the related costs because of the nature of repairs and/or modifications required. This requires that we be a bit more specific in resolving questions concern-ing associated invoices. Accordingly, your proposal is not acceptable, although your gesture is appreciated, and the credit memo in the amount of
$43,333.46 is hereby returned without action.
To clarify matters, let us first review the paid and unpaid invoices in question as they rela'te to four (4) specific elements of the engines. These are the four areas in which we believe Transamerica DeLaval at least shares responsibility.
- 1. CYLINDER HEADS: Have histor cracking prooTems, warpage, y oferrosion metal continuing casting in way and valveareas, of firing-ring' seat carbon blowby into the rocker box area, non-concentric valve seat to guide alignment and more recent problems relating to casting flaws (pin holes which leak water into the cylinder) and chrome failure on exhaust valve stems. The modified cylinder head, which you provided for evalu-ation, may resolve the casting cracking, warpage, and fire-ring problems.
3*e A.i t ? t,94
- n. ._
M/V COLUMSIA Main Propulsion Engin::s July 10, 1979 ATTN: Mr. Martini Page II (Cont'd) Our relieving of the counterbore machined into the exhaust port area during prior valve guide modifications should reduce if not eliminate the carbon blowby into the rocker box area. The matter of casting flaws, valve seat cracking, exhaust valve chrome failure and non-concentric valv-seat to guide alignment is a matter of concern over which we have no con-trol. Aside from our costs for exhaust port relieving, procurement of necesary intake and exhaust valves, related gasket kits including new fire-rings, procurement of buffer springs, valve rotators, etc., the following in-voices are outstanding and questioned as to total responsibility: 28547---Rework of five (5) cylinder heads and return freight--$13,302.50 29084---Rework of ten (10) cylinder heads and return freight--$31,343.29 To tal Shop cos t to rework T5 cyl inder heads . . . . . . . . . . . . . . . - . . . $44,645. 79
- 2. PISTONS: All 32 pistons were removed from the engines for extensive modification as recommended by Transamerica DeLaval. We had no alterna-tive if the vessel was to be returned to service because of the unprece-dented oil and filter contamination problems. Inspectiorr of the pistons revealed heavy carbon accummulations', stuck and/or defective piston rings damaged crown to skirt seals, blowby and heavily wetted cylinders, all of which pointed to a major problem.
The piston modification required ordering the conversion parts which we did on our D.0. #581960. This order included the new style piston ring sets at $14,364.00 and totaled $33,203.10 as per acknowledgement copy of your order number C-08800. Unfortunately, the order was processed via a number of separate invoices upon which our 0.0. number was transposed, making correla tion difficul t. At this writing, I have only been able to locate the following piston conversion part invoices, although payment of the complete order was made. 2 7 3 3 5--- P i s to n co nv e rs i o n pa r ts ----------------------------- $ 5,637.19 2 7192-- P i s to n co nv ers io n pa r t s------------------------------ $20,591. 98 29691 --- P i s to n ca n' vers i o n . pa r ts ----------------------------- $ 70.42 Total cost of piston conversion parts, less freight, as noted on you r order numbe r C-08800. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 538,203.10 In addition there'.0, the following invoices are outstanding: 2884 5---Mod i fy 16 p i s to ns -----------------------------------$11,2 76.4 3 g 2339 5---Mod i fy 16 p i s to ns ----------------------------------- $12,841. 80 To ta l cos t o f p i s ton modif ica tion. . . . . . . . . . . . . . . . . . . . . . . . . . . $24,118. 23
- To ta l cos t o f p i s ton mods i ncl ud ing parts . . . . . . . . . . . . . . . . . . . $62,321. 33 i
I l
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M/'! COLUMBIA F.41n Prupulsion Engines July 10,-1979 ATTN: Mr. Martini Page III (Cont'd)
- 3. CYLINDER LINERS: Machine huning of all cylinder liners was recommend-ed by Transamerica DeLaval in association with the piston modification and new piston ring installation. Again, we found no acceptable al-ternative and 30 of the 32 liners were sent to Oakland for factory honing.
The two (2) other liners were scored beyond reclaimable limits and two (2) new liners 'were ordered. . Cost of liner honing is as noted on these two (2) paid invoices: 2 7 5 9 5 --- Ho n e 14 l i n e r s -- --- --- ------ -- -- ---- ------ -- -------- $ 3,256.00 2 8 2 3 4 - -- Ho n e 16 l i n e r s -- ------- -- -- - --- -- -------------- --- -- $ 8,156.80 Add to the above the cost of the two (2) new liners as noted on the listed paid invoice: 285 78--- Two ( 2 ) repl acement l i ners-------------------------- $ 6,241.65 The total cost for liner rework and/or renewal amounted to..$17,654.45
- 4. BEARINGS: We were concerned about possible effects the contaminated lube oil had on the connecting rod bearings. Inspection associated with piston and liner removals, revealed excessive wear at 17,000 or less hours and plating failure on several of the bearing halves. The e,xcessive wear could only have resulted from the contaminated lube oil. The recent piston and ring modifications may prevent a future recurrence. The plating fail-ure is clearly a Q.C. problem over which we have no control .
Again we had no alternative but to prematurely renew all connecting rod
- bearings even though they should have lasted at.least 40,000/ hours.
Cost of new connecting rod bearings are noted on the following outstand-ing invoices: '
- 29140---32 s h e l l s - - - - - - - - - - - - - - - - - - - - - - - - - - -- -- - - - - - - - - - - $21,968.54 29375--- 6 shells-----------------------------------------$ 5,910.00 29377--- 4 s h e l l s - - - - - - - - - - - - - - - - - - - - - - - - -- -- - - -- - - - - - - - - - $ 3,940.00 To tal cos t o f connec ti ng rod bea ri ngs . . . . . . . . . . . . . . . . . . . . . $31,818. 54 We additionally have the matter of'the main bearings. Inspection o'f selected main bearings, for American Bureau of Shipping Survey, reveal-ed identical bearing failure problems as noted on the connecting rod bearings. Fortunately, we were able to reverse the top and bottom bear-ing shells since the crankshaf t load is primarily on the bottom half. In this case we did have an alternative which was to renew the excessively' worn bearings. Based on latest available data, renewal of the main bear-ings would have amounted to a t least another $15,672.00.
Finally, we have the problem regarding credits for incorrect parts return-m ~r - -- , - - - m -, a y e.- w
M/V COLUtTBIA Main Propulsion Engines July 10, 1979 ATTil: Mr. Martini Page .IV (Cont'd)
- ed .-our facility. In each case we were again billed for the correct parts.
-The invoices in question are noted below:
28898---32 inco rrec t exhaus t val ves----------------------Paid--$ 4,928.00 28971---32 incorrect connection rod bearings---------flot Paid--$17,441.34 The State of Alaska is only desirous of ending up with engines as. originally contracted for. It is to our mutual interest that the long tem engine prob-lems we have experienced, be resolved. We have worked and cooperated with Transemerica DeLaval to that end in the past and intend to continue to do so in the future. Good progress has recently been made. The turbocharger and exhaust manifold modifications are prime examples. We are hopeful that the just_ completed-piston modifications will resolve yet another long tem prob-lem. The results have been most satisfactory todate. The modified cylinder head, presently being field tested on the port main engine, may prove to be-come the answer to the remaining cylinder head problems. 4 In summary, we believe.Transamerica DeLaval must at least share the cost of a portion of the noted repair and modification costs. This is based on our conclusion that the invoices in question are not related to normal wear and tear nor are they the result of some machinery ' casualty or the result of ' operator error or negligence. tJeither are they considered " Product Improve-ments" which basically relate to changes or modifications that exceed the original purchasers specifications. Unlike the fuel nozzle modifications, which was clearly a product _improvemerit, we were left with no alternative but to proceed with the abnormal repairs and modifi, cations noted herein. Accordingly, it is proposed that:
- a. The State of Alaska and Transamerica DeLaval share equally those
- costs specifically noted henein relative to repair, renewal and/
l or modification of the cylinder heads, pistons, cylinder linders ] and cornecting rod bearings. This will amount to $100,582.56 of unpaid invoices and $55,587.55' of paid invo' ices totaling $156,440.1.1.' State of Alaska share would be $78,220.06, less the $55,857.55 already paid against these invoices, for a balance of $22,344.51.
- b. Transamerica DeLaval issue a credit to the State of ' Alaska cover-i ing 50% of the current replacement cost of one half of the engine main bearings. This amounts to one quarter of the cost of two (2) engine sets of main bearings.
' Assuming total replacement bearing costs of $15,672.00, this would amount to a credit to the State of Alaska of $3,918.00. Future m- - w - ,- , gw - na e. ,, , , -
r: . M/V COLUMBIA Main Propulsion Engines July 10,1979 ATTN: Mr. Martini Page V (Cont'd)' replacement costs of these bearings would then be the States responsibil ity.
- c. Transamerica DeLaval issue credits against the following invoices for parts returned:
Invoice #28898 for 32 incorrect exhaust valves returned by RMR-5731-61. Credit due..............................$ 4,928.00 Invoice #28972 for 32 incorrect connecting rod bearings returned by RMR-5731-58. Credit due....................... 517,441.34 Total credi t due for returned parts. . . . . . . . . . . . . . . $22,369. 34 We await your response to this proposal. Mean while, all other. outstanding invoices are being processed for payment. Alaska Marine Highway i
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i Project' Engineer Pier 48 Seattle, Washington 98104 MEZ:abh CC: Robert Ward / Commissioner James Eide/ Director , Merv Griggs/ Administration Officer l Charnelle Howitz/ Finance Of ficer i Tom Eiden/ District Manager--Transam. DeLaval A.H. Mcdonald / Port Engineer t
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.ro [-Robert ~ Ward D^M July 11, 1979 Commissioner Juneau, Alaska 99811 "tt No
/.., itL(PHONE NO.
, l,'/ il ~'. s E sus;eo: M/V COLUMBIA - Main Propulsion Engine
,g3/' Pro Max /jec. Zbinden t Engineer Pier 48 Seattle, WA 98104 Forwarded herewith is a copy of Trgnsamerica DeLaval, letter of June 21, 1979, to which my letter of July 10, 1979, re-pl ied.
The basic letter should have been an enclosure for informa-tion of those persons listed for distribution.. CC: James Eide/ Director Merv Griggs,'Adminis trative Of ficer Charnelle Ho eitz/ Finance Officer A.H. Mcdonald / Port Engineer
A . . ,. c7 C7 c - b b b b JH S Ha:40N0. GoytRM02 Dl!PARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES MAINTENMCEAND CPERATIOt.S OfVISIONOFMARINEHIGHWAYSYSTEA6 July 23, 1979 Transamerica' DeLaval, Inc. Engine and Compressor Division 550 85th Avenue Oakland, California 94621 SUBJ: M/V COLUMBIA - Main Propulsion Engines ATTN: Mr. Douglas Martini
Dear Mr. Martini:
The proposal con,tained in your letter of July 16, 1979, to resolve the invoices in question, is accepted in the spirit of cooperation and goodwill. We are disappointed, however, to find that you could not accept a portion of the costs relating to the premature need for renewal of one-half of the main bearings. ' Sincerely yours,
/ ,
/, .,/
Max' E. Zbinden Project Engineer Pier 48 Seattle, Washington 98104 MEZ:abh
^
CC: Robert Ward / Commissioner James Eide/ Director Merv Griggs/ Administrative Officer Charnelle Howitz/ Finance Officer Tom Eiden/ District Manager---Transamerica DeLaval A.H. Mcdonald / Port Engineer L..
Transamerica D:1: val irr ITBIISBGBi1CB snain. and compre..or Division {g)gijg) 550 85th Avenue P.O. Box 2161
' '1 Oakland, Capfomia 94621 (415) 577-7400 July 16, 1979 State of Alaska Department of Transportation & Public Facilities Division of Marine Highway Systems Pier 48 Seattle, Washington 98104 Attn: .M . Max Zbinden
Dear Mr. Zbinden:
We have your letter of July 10, 1979 and after review we firmly believe we made an honest effort to settle your account. So that the matter can be finalized we have attached the following credit memos:
- 1) To settle account $57,000.00-
- 2) For returned exhaust valves 4,928.00
- 3) For returned rod bear,ings 17,441.34 Total Credits $79,369.34 Net due to Transamerica Delaval - $47,238.28.
We do not accept any responsibility for the main bearings.
' Youth very truly,
..._(,
D.[. Martini
)" sc-
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Vice President and. General Manager l DHM:pt ( Attachment ' cc: T.E. Eiden . G.E. Trussell Ed Staub
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DEPARTNENT OF TRANSPORTATION AND PUBLIC FACILITIES AtAINTENAtoCE AND C?ERATIOhG DIVISIONOFAtARINEHIGMMYSYSTE?& December 26, 1979 Mr. James Eide Director Diviuon of Marine Highway Systems
SUBJECT:
M/V COLUMBIA Main Propulsion Engines RE: Our letter dated February 2,1979, copy attached
Dear M' . Eide:
In Mr. Zbinden's letter dated February 2,1979, the M/V COLUMBIA main engine problems and corrective action taken up to that time were noted. It was estimated that one, possibly two, more seasons of operation could be realized before another complete overhaul would be required. The assumption being that no new major breakdown or failures occurred in the interim. Unfortunately, M/V COLUMBIA'S main engines encountered new problems approximately 115 months before the end of the first season. These new problems consist of failure of connecting rod bearings which were installed new last overhaul period and the cracking of 25% of the connecting rods in both engines. Inspection of the engines during tear-dowry thus far, reveals the existance of new major design problems and continuation of some of the previous problems. There appears to be no. satisfactory resolution in sight. This situation has occurred in spite of exhaustive efforts on the part of the vessels engineering personnel who are considered second to none. The Columbia is not an isolated case. Several other operators of the same engines, in both stationary power plants and marine propulsion applications, are having indentical problems. , The cost and magnitude of past engine repairs, modificatius and overhaul efforts, coupled with those now before us, necessitate a strong hard look with respect to our future actions. We are attaching four different proposals for your consideration. Due to the amuunt of money involved and the inevitable reduction in service. I do not feel that it is in the best interest of the State of Alaska to proceed any further with any modification or repairs of the vessels machinery without considered opinons from your office, and others who may be involved. If a conference on the subject is necessary, we can certainly find the time to meet with you in Juneau at your convenience.
- Respectfully yours.
PORT ENGINEER Pier 48 Seattle, Washington 98104 AHM/vf 25 A.7 3 2 LM .
PLAN 1 Stop all work on the II/V COLUMBIA main engines and immediately start on plans for renewal of the engines with an in-depth study by a qualified Marine Engineering finn as to propulsion package options, ect,. Vessel would therefore be out of service during 1980 season.
- 1. Apply cost of programmed camshaft mods (75,000.), mods to exhaust 1
manifolds (35,000.), and estimated cost of approximately (350,000.) of repair to engine connecting rods, bearings, ect., toward engineerim. and the re-engine project, including possibly change cut of auxil.ary generator units. 9 4
PLAN 2 I Reassemble M/V COLUMBIA main engines with minimual expenditure of funds. Place vessel into service only during peak passenger period, four months maximum, from June through Septenber 1980 and hope that we can keep her on the line. Start l immediately on plans for re-engining with an in-depth study by a qualified I Marine Engineering fim.
- 1. Delete camshaft mods.
(Save 75,000. on parts)
- 2. Renew only the four cracked rod assenblies and damaged rod bolts.
(Cost approximately 25,000. for parts) 4;.
- 3. Renew bearing shells as necessary.
(Cost approximately 20,000 for parts)
- 4. Recondition cylinder heads (32 each).
(Estimated e.ost approximately 10,000. for parts)
- 5. Clean all four turbo-chargers and repair cracked nozzel piece.
(Estimated cost approximately 25,000. for L&M.)
- 6. Would still have to repair exhaust manifolds on both engines.
(35,000. in budget to cover) Would still have to repair ships service generator and emergency penerator set. M ,
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PLAN'3' Completely rebuild both main engines incorporating latest engine. manufactures design modifications. This would _ require vessel remain out of service for accomplishment of the necessary work until approximately,'fiay 1980. Cost would approximate 450,000/500,000 plus 110,000. already programmed for camshaf t repairs and exhaust manifold mods. The results would not assure reliable vesse' operation throughout the 1980 season and would not eliminate continuation of existing engine problems in following years l ) r I I e
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PLAN 4 Completely rebuild both main engines as noted in PLAN 3. Additionally derate the main engines to approximately 5500 HP each at 375 engine RPM. This would require modifications to camshaf ts a'nd engine timing, changes to the fuel system, changes to the turbo chargers, changes to the propeller pitch / control system, ect., which would require some engineering efforts. Since such items as turbo charger changes camshaft changes and pitch / control mods could not be developed in time for incorpore by mid 1980, the vessel would only be utilized on a 4 month period as noted in PLAN 2 to minimize any further damage until the engines can be totally derated. The plan for derating is based on the fact that the " Blue Class" vessels have satisfactorily operated at 375 engine RPM developing 4000 HP each for approximately 15 years utilizing basically the same engine. From all available data, it appears that when the engine speed was increased above 375 RPM to provide more horsepower, the basic engine components began to fail apparently due to accelerated wear and increased loading. Identical engines in the field operating at 400 RPM are having similar problems as in M/V COLUMBIA. Columbia is rated at 450 RPM-This change would still leave us with possible, piston, cylinder head problems and liner seal problems, since the Columbia and "51ce Class" do differ in these respects.
i Transamerica celavalInc. TTBilS922I108 enene ano com,,,,,,, om.,on pg) 550 85th Avenue P.O. Box 2161
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M" oaktarsd. Canfornia 94621 (415) 577-7400 l::1 I I January 23, 1980 State of Alaska Depart.ent of Transportation & Public Facilities Division of Marine Highway Systems Pier 48 Seattle, WA 98104 Attention: Mr. Max E. Zbinden Project Engineer
Subject:
M/V Columbia, Delaval Enterprise Engines S/N 72033-34
Dear Ma.:
Thank you for your letter dated January 16, 1980 and addressed to our Mr. D. H. Martini. Please find this letter in response to your letter. We agree that a meeting between now and the end of the Jnonth is in order. It is proposed that the meeting be held here in Oakland on Thursday, January 31, 1980. We are now in receipt of the four connecting rod boxes and should have our analysis
! complete and ready for discussion by the 31st. We have not yet received the cylinder heads, but anticipate having those in house with our analysis in hand also for the 31st meeting.
The 31st meeting in Oakland should also make it possible to have such involved individuals as Clint Mathews, Bud Trussell, Hal Schilling and Steve Schumacher. Please advise your availability at the earliest opportunity and we will pursue final arrangements. Very truly yours, TRANSAMERICA DELAVAL INC. Engine and Compressor Division 8
- 8. J. Durie Manager . Customer Service ncb l
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DEPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES h%INTENANCEAND CPERATIONS DIVISIONOFMARINEHIGMVAYSYSTEMS l l January 22, 1980 TRANSAMERICA DELAVAL, INC. Engine & Compressor Division 550 - 85th Avenue---P.O. Box 2161 Oakland, California 94621 SUBJ: M/V COLUMBIA; Engine Part Shipments S/N 72033/34 ATTN: Mr. Dick Desrumeaux
Dear Mr. Desrumeaux:
Please be advised that four (4) each cracked connecting rod assem-blies have been shipped to your facility on RMR-5731-63. The rods 4 are to be fitted with new link rod boxes and be up-dated -with 12 " 3 bol ts, etc. Charges shall be costed against our DO #587080. A separate shipment consisting of eight (8) cylinder heads is being shipped to your facility 'on RMR-5731-64. The shipment will also in-clude defective rod bolts, defective valves and cracked push rod ends as requested. The heads are cracked across the vilve seats, and in some cases, into the parent head materials. All require rework or replacement as the case may be. Charges shall'be costed against our DO #587081. For record purposes, the cylinder heads being shipped are as follows: F-83, E-72,.A-59, A-27, F-28, A-2, F-75, and D-2. The latter head is the reconstructed unit provided last year for operational testing. j Sincerely .M Y . ,s
,'$/.f '/ / (l t w . J' Project E gineer Pier 48 /
MEZ:abh Seattle, Washington 98104 CC: Chief Engineer /M/V COLUMBIA A.H. Mcdonald / Port Engineer Michael Britt/ Sales Manager...TRANSAMERICA DELAVAL
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-Merv Griggs/ Administrative Officer Janua ry 18, 1980 Based on the plan noted in our letter of January 16, 1980, to TRANS-AMERICA DELAVAL, INC., monies required in addition to the programmed funds is as follows:
- 1. Repair and reconditioning of the cracked connecting rods including new link rod pins.
Labo r and ma te ria l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .EST. $36,000.00
- 2. Replacement connecting rod bearing halves.
Material...........................................EST. $16,000.00
- 3. Replacement cylinder head valves.
Ma t e r i a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E S T. $ 3,000.00
- 4. Replacement push rods.
Material...........................................EST. $ 1,000.00
- 5. Replacement rod bolts.
Material...........................................EST. S' 1,800.00
- 6. Repair inner and after coolers.
Labo r a nd ma terial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EST.- $20,000.00
- 7. Repair or replacement of cracked' cylinder heads.
If repairable - Labor and material...(EST. $25,000.) If replacement required - material...(EST. 562,000.) As sume 50% a re repa i rabl e. . . . . . . . . . . . . . . . . . . . . . . . . . EST. $4 3,500.00
- 8. Clean and balance turbochargers.
Labor and material.................................EST. 5 3,000.00
- 9. Turbocharger modifications.
The 20 to 24 weeks minimum lead time precludes action this repair period, however, the parts must be ordered now for next year. La bo r a nd ma te ri pl . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EST. $125,000.'00 This amounts to a total of.........................EST. $249,300.00 Exclusive of freight charges for main engine repairs. Additional funds are requried to effect unprogrammed necessary repairs to the ships service generator units. L a b o r a nd ma te ri a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 75,000.00 Thi s amounts to a grand total required of. . . . . . . . . . . . . . . . . $324,300.00 Max Zbinden
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Y @ 0,f f l c l k to N b.m'"1 N !7d .' '" "'"#"A "" DEPART.\ TENT OF TRANSPORTATION AND PUBLIC FACILITIES MAINTENAfCEAND CPERATICtB * [ DIVISIONOFMARINEHIGrM:4 YSYSTE.tG ! January 16, 1980 TRANSAMERICA DELAVAL, IllC. Engine and Compressor Division 550 - 85th Avenue---P.O. Box 2161 Oakland, California 94621 SUBJ: M/V COLUMBIA - MAIN PROPULSION ENGINES S/N 72033/34 ATTN: Mr. Douglas Martini
Dear Mr. Martini:
As a result of the extensive overhaul and modifications completed last year, it was estimated that one, possibly two seasons of opera-tion would be realized before another nafor teardown and overhaul were required. The assumption being that no new major failures or breakdown occurred in the interim. Unfortunately, M/V COLUMBIA'S main engines encountered new problems necessitating the vessels ~ removal from service'l months befors the end of the nonnal season. The new problems concern cracking of 25". of the connecting rod assemblies in both main engines and 40% of the newly installed upper connecting rod bearing halves. Subsequent teardown of the engine has additionally revealed the fol-lowing: (1) The heavy fretting of the jaw areas between the master and link rod boxes continues and is indicative of a ser-ious design problem. (2) Fretting is also evident between the link rod and the link rod pin and heavy wear is occurring between the link rod bushing and the pin in way of the small lubricating oil holes. (3) A total of 10 cylinder heads have cracked valv5 seats. In several cases the cracks extend into the parent head
- - material. Eight of these heads require repair before further use.
- l. (4) A total of 15 valves are defective with chrome flaking off of the valve stems the prime problem as before. However, l we see a new condition wherein the valve stems are l
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TRANSAMERICA DELAVALo INC. January 16, 1980 , Engine and Compressor Division Page Il
'SUBJ: M/V COLUMBIA - MAIN PROPULSION ENGINES S/M 72033/34...(Cont'd)
ATTH: Mr. Martini ' apparently being impacted at the keeper area. This has caused upsetting of the valve stem material to the point that the valves could not be removed fr the guides with-out first grinding away the upset are~ (5) Five (5) more push rods are cracked one same manner ex-perienced in the past. (6) The port main engine turbo air cooler inlet housing is cracked for the fourth time. (7) Internal bracing in the main engine intercoolers are cracked. The above conditions have occurred in 4500/hcurs of engine operation. We still have the cracked exhaust manifold problems and the camshaft problem left over from last year to deal with. The saga of the M/V COLUMBIA'S main propulsion engines continues in spite of unrealistic and repetitive expenditures of funds and labor man / hours each year. The original engine deficiencies, for the most part, have not been resolved todate and problems new to us are now de-veloping. This, coupled with budgetary limitations, have resulted in the following program for 1980.
- 1. Main engine camshaft repairs, originally programmed for this repair period, are cancelled .for the time -being.
- 2. Repair and modify only the four cracked , connecting rod as-semblies.
- 3. Renew those connecting rod shells that are cracked.
- 4. Repair eight of ten cracked cylinder heads.
- 5. Renew the 15 defective valves.
- 6. Renew the five cracked push rods.
- 7. Make no turbocharger conversions this year since we cannot live with 20-24 week delivery.
- 8. Proceed with the exhaust manifold mods since we have no al-ternative at this time due to total failure of the outlet end.
- 9. Effect repairs to the air cooler' inlet housing and the crack-ed brackets in the four intercooler assemblies
- 10. Recondition cylinder heads / valves as necessary.
This action should permit operation for a four month period during the peak seasonal period, barring additional connecting rod and/or similar failures. It will also provide for breathing time to eval-uate various options concerning the main engines that are open to the State. I
TRANSAMERICA DELAVAL, TNC. January 16, 1930 Engine and Compressor Division Page III l SUBJ: M/V COLUMBIA - MAIN PROPULSION ENGINES S/M 72033/34. . . ( Co nt' d ) ATTN: Mr. Martini One of the options concerns derating of the engines which would re-quire changes in the fuel system, possibly camshafts, timing, turbo-chargers, engine control and propeller pitch systems, etc. Another would be to continue as we have been, which has not provided the nec-cessary results to date. Still another option would be to completely rebuild both engines incorporating the latest engine manufactures de-sign modifications and see what overall benefits would be gained by this action. It is therefore necessary that a meeting be held in Seattle, as soon as practicable, and no later than February 1,1980, to review and dis-cuss these options. From this we hope to establish plans concerning the main engines.on the M/V COLUMBIA. Sincerely,
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.- //kf '.W,'/ %d Max'E./Zbinden Project. Engineer Alaska. Marine Highway Systems Pier 48 Seattle, Washington 98104 MEZ:abh ,
CC: Robert Ward /Commir..oner James R. Eide/ Director A.H. Mcdonald / Port Engineer
i J C4:81ee.10/144 ALASKA / // ro Frile onE. February 5,1980 FILE NO TELEPHONE NO
- r H>+ Max E. Ibinden sus;tct: Meeting with Transamerica DeLaval Project Engineer in Oakland, Cali fornia. . . . . .
Pier 48 , RE: M/V COLUMBIA - Main Engines Seattle, WA 98104 Arrived in Oakland, California, at approximately 9:20 AM, January 31, 1980, and met Mr. Douglas Martini at approximately 9:55 am, at the DeLaval/Trans-america office. Commenced meeting in their conference room with the follow-ing people in attendance: Mr. Douglas Martini /Vice President & General Manager, Engine & Compressor Division. Clint Mathess/ Assistant Manager Bud Trussell/ Engineering Manager Bert Durie/ Service Manager Harold Schelling/ Failure Analysis Engineer Michael Britt/ Seattle Office Sales Engineer Opened meeting by displaying the damaged lower taper piston rings recently discovered during piston clean-up action. Advised them that rings installed with .005" side clearance as per Bob Grey, DeLaval Rep. in attendance during engine re-assembly. The small side clearance questioned by vessels Chief Engineers, at that time. Further advised that side clearance now around .013"- t
.014", DeLaval indicated that problem caused by mistakh -in their drawing their shop followed. I express displeasure in that we paid them for the piston mods last year and we will now have some additional rework costs due to their error.
Similar to exhaust manifold goofs, etc. , in the past. They recommended we leave off the two rings we removed, since machining would be required to remove the piston ring groove upset material before new rings should be installed. I agreed and questioned the status of the remainder of the 32 pistons. They recommended leaving the rings in place since the clearance has nov been attained through the pounding action caused by the original insufficiencies side clearance problem. Pistons will have to be reworked later ..will last four (4)/ months. Advised we would make decision to leave or remove the remainder of the lower taper rings. I then advised them as to the reason the meeting was requested. I advised them that the M/V C0ltWBIA, the second ntwest vessel in the Alaska Marine ; Highway Systems fleet of nine vessels, is the only one that is repeatedly unable to perform because of main engine problems. The intent of the vessel, when built, was to provide year around mainline , ferry service between Seattle, and Alaskan Ports, which was expanding. Since ! delivery to the State of Alaska, the vessel has been plaqued with a long series of main engine difficulties. Many have resulted in vessel tie-up for i i l 4 l I
l l I February 5,1980 ! Page II SUBJ: Meeting with Transamerica DeLaval in Oakland, Cal i fornia . . . . RE: 'M/V COLUMBIA - Main Engines---(Cont'd) e repair action of various lengths and delayed or concelled sailings. The effects, on system schedules and passenger service as well as the Marine ! Highway reputation, has not been good. In spite of continued tear-down, overhaul, the infusion of new parts and expenditures of unpresidented labor man / hours, over a period of Sh/ years the vessels main engines are still unable to perfonn properly or realiably. The State cannot continue operation of the M/V COLUMBIA as in the past in-sofar as the propulsion engines are concerned. We must.either resolve the engine problems in one way or another or the State must seriously start movement toward re-engining the vessel. The latter option is least desirable due to the time frame required for such a move and the costs involved. Resolution of the existing engines many problems is the preferred course of action and could take several directions. One would be the permanent resolution of existing and known engine problems to provide for reliable propulsion engines capable of operating at design rated power. Should this not be possible in relatively 'short order, the possibility of derating the engines may become necessary, to reduce the BMEP and related forces to a livable level. The point of this meeting requested between the State of Alaska and DeLaval, is to establish the position we have been placed into and determine if it is possible to once and for all resolve the enginer problems and if derating of the engine is in order, develop the changes necessary to accomplish same. In both cases, what would be entailed as to changes, _ modifications, costs involved and whether participation by DeLaval in sharing or absorbing costs is likely, and to what extent, and . time frame associated therewith is de-sired. After comments by Mr. Martini, and others, as to assurance of their help and a dislike in having to consider engine derating, we proceeded into looking at the cut open sections of our cracked connecting rods. Harold Schilling i carefully explained his analysis of the failures and furnished several sketches. As a result of this analysis, it was agreed that we should look again at those connecting rods that revealed no cracks but had cracked bearing shells. I The same for those rods that had damaged bolts and/or threads. We'may find l that additional rods will require rework, accordingly. i ! Revised tnrque valves were furnished as follows: Link rod to pin - 1050 ft. lbs.
February 5, 1980 Page III SUBJ: Meeting with Transamerica DeLaval in Oakland, California. . . RE: M/V COLUMBIA - Main Engines---(Cont'd) New lh" rod bol ts - 1700 ft. lbs. Ol d rod bol ts ----- 2600 f t. lbs. Mr. Trussell was not concerned over the fretting of the piston faying sur-face and commented on research being done on pistons. Mr. Schelling recommended tcc check rod boxes to assure maximum out of round-ness at .004". Also to take another good look at the rod bolts and thread in view of the analysis results and the rods that had cracked shells although the rod itself revealed no apparent cracking or failure. The matter of insufficient turbo air manifold pressure, was discussed. Mr. Mathews did not see it as a problem since records indicate sufficient air and proper exhaust temps at. normal operating speeds. I advised I would dig up info and send it along on this item. He also questioned the carbon deposits on the piston and head assemblies. I did not have data at my finger tips. However, after return to the vessel it was clear that the carbon deposits, or the upper end of the piston, are hard. Elsewhere they are sof t. Rocker boxe are still dirty and carbon balls are noted on the valve ' stems. As for the manifold pressure it was noted that during the run from Seattle to Ketchikan, and VS , the pressure is satisfactory. However, three days each week, when underway, requires reduced speed operation such as when traversino narrows, passing close to villages, awaiting favorable tides, etc. many hours of operation with manifold pressures,as low as;4 PSijare not ab-normal. We attempt to regulate the engine speed to the point that we do not cause the turbo air seal compressor to continuous cycle. The meetings were concluded with assurance from Mr. Martini that Transamerica DeLaval would participate in resolution of the M/V COLUMBIA problems. Mr. Durie was to confirm the revised torque values and similar suggestions by letter to Alaska Marine Highway Systems. At the last moment I was, handed a marked up copy of balances due Transamerica DeLaval. After returning to Seattle, I found that several were a part of the settlement made last year and previously processed for payment. This situ-ation will be addressed by separate correspondence to Juneau. B
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OliPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES MAINTENANCEANDCPERA TIOfB l DiVISICN OFMARINEHIGhWAYSYSTE!2 ,! February 29, 1980 Transamerica DeLaval Engine & Compressor Division 550-85th Avenue - P.O. Box 2161 Oakland, California 94621 SUBJ: M/V COLUMBIA - Main Propulsion Engines S/N 72033/34 ATTN: Mr. Bert Durie
Dear Mr. Durie:
Review of your letter of February 20, 1980, reveals the continuing dis-parity between Transamerica DeLaval and the Alaska Marine Highway System as to the cause and severity of the problems with the M/V-COLUMBIA'S main engines. The damage sustained by the. number four compression rings, sample furnish-ed at our January 31, 1980 meeting, is deemed considerable in lieu of an indication of "some galling". So is the upsetting of the metal in the as30ciated ring groove bounded by both ~the crown and skirt assemblies. This condition apparently occurred due to some action which hammered or jammed the ring in the groove at some considerable force. ~ This caused an increase in the groove and ring side clearance by appr1ximately .007" in 4500 hours operation. Whether this also had an effect on the " frosted" appearance in the fretted areas on the mating surfaces of the piston crown and skirt is unknown. ' Since the damage to the pistons and number four compression rings result-ed after piston modffications by your facili_ty, Transamerica DeLaval is expected to ultimately provide permanent corrective action. In the in-terim we shall, as you recommended, reinstall ane operate with the pistons as is, subject to ABS approval. We remain concerned over the variations in the torque of the piston crown to skirt nuts. If they are initially installed with at least 85 ft. lbs. and at a maximum of 100 ft. lbs. torque, why is it that we find two of four such nuts on one assembly at 75 ft. lbs. and an~other at 120 ft. lbs? Was not one feature of the piston modification to provide for more secure fastening of the crown to the skirt? . You did not comment on the apparent chrome failure on the number three
Transamerica delaval Februa ry 29, 1980 Engine & Compressor Division Page II SUBJ: M/V COLUMBIA - Main Propulsion Engines S/fl 72033/ 34. . . ( Con t 'd ) ATTN: Mr. Durie piston rings observed during our meeting in Seattle, on February 7, 1980. This again occurred at 4500 hours of operation and could be a material or QC problem. Please be advised that a fifth connecting rod has been shipped to your-3 facility for rework as the previous four. Two additional cylinder heads were also returned for renewal of the valve seat hard facing. Exception is taken with your conment that the damage to some of the link rod bushing bail areas was caused by foreign material in the lube oil . Mr. Schilling, also, prevously stated that it was caused by dirty oil. We are all aware of the history of dirty oil and short filter life on the M/V COLUMBIA'S main engines. The condition, you will remember, for-ced the early removal of the vessel from service, season before last. The dirty oil did no doubt effect the various lubricated portions of the engine. However, in this case, the damage to all link rod bushings was not consistant throughout as would be the case with yourand Mr. Schilling' ra tional , i We see a marked difference between the conditions of the various link rod bushing bail areas. In each case wherein bushing bail damage was evident, the matching. link rod pin revealed a heavy worn or polished area around the drilled oil passage hole which lines up with the bail. Where the bushings showed no damage in way of the bail, no worn or pol-ished area on the pin around the drill oil passage was evident. From this we must conclude that the drilled oil passages, in some cases, were not properly relieved during manufacture. The remaining raised area or burr, around the oil hole, is therefore deemed the cause of link rod bushing damage in the bail area. On another subject, you are advised that Alaska Marine Highway System is , alarmed over the status of repair action and part support thus far with l respect to the M/V 40LUMBIA. As of yesterday we were advised of the fol-
- lowing based on a telephone inquiry:
- 1. That the four connecting rods, in your possession since the end of January, for rework, will not be ready for return for another 5 or 6 weeks.
l 2. Four of the eight cylinder heads, in your possession since the end of January for repair, have teen inspected. The remainder will be inspected and we will be notified by the end of next week as to the repairs required. Return date unknown.
- 3. The four exhaust manifo,ld repair kits, on order since July,1979,
4 Transamirica DeLaval February 29, 1980 Engine & Compressor Division Page III SUBJ: M/V COLUMBIA - Main Propulsion Engines S/N 72033/34...(Cont'd) ATTN: Mr. Durie and previously indicated as being shipped out in October,1979, should be ready in "about" 3 weeks for shipment.
- 4. Of the 10 link rod ordered, three can be shipped out this week and the remainder will not be available for a month.
The established time frames for producing parts and accomplishing neces-sary repair action is totally unacceptable. We would never be able to resume the planned limited service starting on May 23, 1980. It is strongly suggested that steps be taken to expedite the above action and we be so advised. Sincerely, l ^ l Max oinden Pro e t Engineer Pier 48 ~ Seattie, Washington 98104-CC: DouglasMartini/ General Manager, Transamerica DeLaval Robert Ward / Commissioner James Eide/ Director' Merv Griggs/ Administrative Officer A.H. Mcdonald / Port Engineer
- M/V COLUMBIA / Chief Engineer l
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DEPART.'.1ENT OF TRANSPORTATION AND PUBLIC FACILITIES A*A INTEtattEANDCPERATIC?2 r
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CIVISIONCFMARINE HIGHYMYSYSTEAG l
. March 24, 1980 Transanerica DeLaval, Inc.
Engine & Compressor Division 550 - 85th Avenue Oakland, California 94621 SUBJ: M/V COLUMBIA - Main Propulsion Engines S/N 72033/34 ATTN: Mr. Douglas Martini-
Dear Mr. Martini:
Our letter of January 16, 1980, noted a number of new and some con-tinuing problems with respect tc the Propulsion Engines on the M/V COLUMBIA. Several of these were brought up in the Januar.y 31, 1980, meeting at your facility. No permanent solution or corrective action was made at that time. I The matter was again brought up in our letter of February 19, 1980. It was requested that we be advised of what action Transamerica De-Laval is taking toward resolution of the prob 4e:ns with the M/V COLUMBI A'S Propulsion Engines. Nothing is known to have transpired to-date. The following is a sumary of the problem areas which need to be addressed. Areas where corrective action has been taken since vessel delivery, and the status thereof, is also noted; A. CONTINUING LONG TERM PROBLEMS:
- 1. Warpage of cylinder heads.
- 2. Fire ring burn out.
- 3. Cracking of valve seats and cylinder heads.
- 4. Warpage of exhaust valve seat area.
- 5. Concentricity problems with respect to valve guides and seats.
- 6. Premature need to renew valve seat facing material .
- 7. Chrome failure on valve stems.
- 8. Abnormal carbon deposits and formations on pistons and cylinder head assembly.
- 9. Failure of push rods wherein tube cracks at attach-ment of end sections.
- 10. Fretting of jaw areas of connecting rods.
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Teansamerica Odlaval, fnc. March 24, 1980 Engine & Compressor Division - ~Page II SUBJ: M/V COLUMBIA - Main Prnpulsion Engines S/M 72033/34...(Cont'd) ATTN: Mr. Douglas Martini
- 11. Chrome failure on piston rings.
- 12. Insufficient turbo (manifold) air except at near full speed operation.
B. PROBLEMS UNCOVERED DURING THE 1978 SEASON...and during the 1978-79 engine tear-down and rebuild at 17,000/ hours operation:
- 1. Premature wear down of original connecting rod and main bearing shells.
- 2. Fretting between aluminum rod bearing shells and rod i bearing bore.
- 3. Failure of hard facing on camshaft fu'el cams.
- 4. Cracked exhaust manifold end plates.
- 5. Excessive wear on valve stems in way of valve guide oil seals, previously installed.
C. PROBLEMS UNCOVERED DURING THE 1979 SEASON. . .and during the 1979-80 engine tear-down and rebuild at 22,000/ hours opera-tion:
- 1. Cracking of connecting rod boxes.
- 2. Cracking of newly installed connecting rod bearing shells at 4500/ hours.
- 3. Fretting of link rod and litik rod pins at their attach-ment together. ,
- 4. Fretting between link rod bushings and link rod bush-ing bore.
- 5. Galling of link rod bushings in way of link rod pin outer drilled oil passages.
- 6. Improper wear / contact pattern on newly installed con-necting rod bearings at 4500/ hours. Four point load-ing.
- 7. Insufficient connecting rod bearing wear / contact area to' journal wherein it is less than 15 ". of the total bearing area.
- 8. Upsetting of stems in valve keeper area.
- 9. Damage to number four piston ring and ring groove on all pistons modified during the 1978-79 engine tear-down and rebuild after 4500/ hours operation.
- 10. Fretting bc tween piston crown and skirts at 4500/ hours since piston modifications.
- 11. Variations in piston bolt tongue, beyond specified limits, at 4500/ hours since piston modifications.
- 12. Damage to rod bolts, including cracking, and damage to
I Transamerica DeLaval o Inc. Ma rch 24,1980 Engine 3 Compressor Division Page III ' SUBJ: M/V COLUMBIA - Main Propulsion Engines S/N 72033/34.. (Cont'd) AT TN: Mr. Douglas Martini ! l l threads on both the bolt and in the rod boxes. D. ACTION TAKEN SINCE VESSEL DELIVERY:
- 1. Original leaking liner seals were r_enewed. Under-stand new cylinder liners now fitted with three seal rings in lieu of two.
- 2. Fire rings changed out. Problem remains.
- 3. Modified turbocharger nozzle ring design and bolting configuration. No turbocharger-damage sirice.
- 4. Changed out original turbo unit with defective bear-ing support housing. No problems since.
- 5. Added external turbo air seal system. No problems since.
- 6. Modified valve guides. Machining caused counter-boring which deflected exhaust gases. Corrected by owner. Addition of valve stem oil seals causes val-ve stem oil seals wear. See i teni---BS) .
- 7. Plug welded rocker assembly drilled oil ' passages to reduce oil flooding of rocker boxes- .
- 8. Installed relief passages in cylinder heads to per-mit combustion gases, leaking past fire rings, to vent into engine room. Prior to this, the gases would enter the jacket water system and cause air binding of circulating pumps. ,
- 9. After several unsatisfactory attempts to resolve ori-ginal exhaust manifold problems, developed water jacket uni ts . All four suffered failure after the first years operation. (See item B4)
- 10. Major piston modifications made during the 1978-79 engine tear-down and rebuild. Has reduced excessive oil consumption and short lube oil filter life, thus far (4500/ hours operation). Problems still exist. (See items C9, C10, and Cll).
l 11. Shifted to exclusive use of number 2 Diesel Fuel as per recommendation. Negative resul ts. Owner elected to re-main on diesel fuel operation, at that time, due to lack of cost differential.
- 12. Changed original rod bolts to those with rolled aircraft type threads. Problems continue (See item C12).
- 13. Changed out piston rings. Problem continues with chrome failure.
14 Installed reportedly new type connecting rod bearing i shells during 1978-79 engine tear-down .and rebuild. Has
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- Trnasamerica DeLaval, Inc. March 24, 1980 Engine ?. Compressor Division Page IV SUBJ: N/V COLUMBIA - Main Propulsion Engines S/N 72033/34. .(Cont'd)
ATT:l: Mr. Douglas Martini j developed into a new problem. (See item C2). While the above summary may not be complete, it does cover the areas of major concern at this time. We are living with other problems such as the repeated necessity to frequently retorque the vibration damper drive hub onto the crankshaft. In any case, it is again requested that we be advised as to action Transamerica DeLaval intends to take, or is working toward, regarding permanent solution to these many problems. As previously noted, these must be sound engineering resolutions and must be coupled with time frame and cost data. Continued operation of the M/V COLUMBIA, with the installed propulsion engines, will depend a great deal upon your reply. Sincerely, j'.' , - ' Max E binden Project Engineer Pier 48 Seattle, Washington 98104 MEZ:abh CC: Robert W. Ward / Commissioner Ron B. Lind/ Deputy Commissioner James R. Eide/ Director Merv Griggs/ Administrative Officer A.H. Mcdonald / Port Engineer Chief Engineer /M/V COLUMBIA Bud Trussell/ Engineering Mgr/Transamerica' DeLaval . . 0akl and, CA. Bert Durie/ Service Mgr/Transamerica DeLaval .. 0akland, CA. Michael Britt/ Sales Mgr/Transamerica DeLaval ... Local Rep. 1 i l
l l Transamerica Dil:v;l Inc. IT85S9 MBT 5DS entne ana Come,e..., oi.,, ion gygj 550 85th Avenue P.O. Sox 2161 1t i Oakland, Califomia 94621 -
." (415) 577-7400
'.. .J June 2, 1980 State of Alaska Department of Transportation
& Public Facilities Division of Marine Highway Systems Pier 48 Seattle, Washington 98104 ATTN: Mr. Max E. Zbinden Project Engineer SUBJ: Cylinder Head S/N 72033-34 M/V Columbia Purchase Order 589268 Delaval Sales Order C-20872
Dear Mr. Zbinden:
The cylinder head assembly supplied on subject purchase order, part number lA-6241-ABS, superceded part number 1A-7019-ABS. The IA-6241-ABS has a less severe seal in the top end of the intake valve, guide. The new seal, part number JA-048-000, does not starve the guide for oil. This change in seals necessitated a change in the valve guide itself. The old valve guide was 03-360-08-AB and the new guide is 03-360-08-AC. The seals (F-161-004), in part number 1A-7019-ABS cylinder head are not inter-changeable with the seals (JA-048-000) in part number lA-6241-ABS cylinder head. You may want to stock some of the JA-048-000 seals for use in the IA-6241-ABS cylinder head. Please note that the valve rotators are included in the 1A-6241-ABS assembly to improve the valve life. Sincerely,
/
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~ g3j'[g9 f- C=^L ) ' Parts Sales LB:kt ec: D. Thomsen, Seattle District Office Parts Book
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if-ft- P l l Web M/V COLUMBIA - REPAIR PART STATUS 7/27/79; Ordered exhaust manifold conversion kits from DeLaval for installa-
- tion during routine repair period.
9/15/79; DeLaval entered above order with shipping date of 10/30/79. 10/05/79; Issued orders to DeLaval for parts and labor to rebuild right I and left bank camshaft assemblies on port and starboard main I engines. Work' to be accomplished.during routine repair period. j 11/29/79; M/V COLUMBIA taken out of service prematurely due to cracking of connecting rods in both main engines. 11/30/79; Advised DeLaval by TEXLEX of above problem and availability of the vessel for inspection in Seattle, 12/06/79; DeLaval representative arrived and looked at damaged parts removed from the engines thus far. Did not provide any answers or resolutions. 12/12/79; DeLaval advised that forgings required to fabricate replacements for the cracked connecting rod link boxes are due in Oakland on 1/11/80. 12/13/79; DeLaval Failure Analysis Engineer, arrived and spent two (2) days looking at damaged engine components. 12/19/79; Called DeLaval as to their recormtendations resulting from the above inspection. Received little direction and requested that complete details be confirmed in writing.- 12/21/79; DeLaval advised that the cracked connecting rods be sent to Oakland for rework. 1/11/80; DeLaval furnished control number for use in identifying the ship-ment of cracked connecting rods to Oakland for rebuilding. Requested and received control number for use in identifying the shipment of cracked cylinder heads, subsequently found. 1/16/80; Sent letter to DeLaval requesting meeting in Seattle to discuss the engine problems and planned course of action. 1/18/80; Shipped four (4) cracked connecting rod assemblies to Oakland for rework. Shipped eight (8) cracked cylinder heads to Oakland for rework. One of these heads was the improved head we were testing for DeLaval, 1/21/30; Issued orders to DeLaval for repair of the cracked cylinder heads and connecting rods. (1)
M/V COLUMBIA - REPAIR PART STATUS - (CONT'D) 1/23/80; DeLaval' agreed to a meeting but suggested it be held in Oaxland at their facility on 1/31/80. 1/31/80; Meeting in Oakland at DeLaval facility. Discussed past and present engine problems and jointly inspected the cracked rods and cylinder h'eads shipped down to them for repair. Probable causes of the rod failures were discussed. However, no real resolution of past or present continuing problems were offered. 2/07/80; DeLaval representative visited the M/V LOLUMBIA per our request be-cause of the number of defective connecting rod bolts found and the heavy fretting noted in the link rod bushing bores, re-- sulting from inspection areas suggested by DeLaval during the
, 1/31/80 meeting in Oakland.
2/22/80; Sent letter to DeLaval cancelling the orders placed on 10/5/79, for parts and labor to rebuild the camshafts on the port and star-board main engines. This was deemed necessary because budget-ed funds were required to cover cost of repairs to cracked rods and cylinder heads. Additionally the unplanned necessity to tear both engines down again, did not permit sufficient time to remove the camshafts as originally. planned. It is hoped that the existing camshafts will last the four months planned operation. The order will have to be reinstated after July 1,1980, (FY 1981 funds) for accomplishment after the four months planned operation. 2/27/80; Advised DeLaval that one more connecting rod and two more cylinder heads were being shipped to Oakland for rework. DeLaval advised that first four rods would be ready for shipment in 5 to 6/ weeks (approximately April 4). That four (4) of the eight (8) heads sent down have been inspected. When the re-mainder have been looked at, they would advis a us of the re-pair required. We had already advised them of the problem and each head had been so marked prior to shipment. They were so informed and displeasure expressed in that little had been accomplished thus far even though the heads had been in their possession for a month. DeLaval additionally advised that the exhaust manifold kits would be ready for shipment in three (3) weeks, (end of March) and that three (3) link rod bushings can be shipped out this week l with the remaining seven (7) bushings in about a month (end l ofMarch). 2/29/80; Sent letter to DeLaval concerning unacceptable time frame regarding i part status and shipments. No reply to date. . . 3/11/80; Called Mr. Martini, at DeLaval, concerning part status. Was ad-vised the following; (2)
c ) 1 M/V COLUMBIA - REPAIR PART STATUS - (C0?1T'D)
/ ,
Will ship seven (7) heads on 3/25/80 Will ship remaining heads on 3/31/80
. Will ship four (4) manifnid kits on 3/31/80
.y Will ship seven (7) link ' rod bushings on 3/31/80 Will ship the connecting rods on 4/15/80-3/24/80; Sent letter to DeLaval 'oncerning c engine deficiencies and problems with request for planned action. flo reply to date.
4/02/80; Called DeLaval .for part status and was advised the following: Seven:(i7) bushings were shipped on 325/80. The four (4) exhaust manifold kits should be shipped on 4/8/80. The cylinder heads should be shipped 4/8/80. One conr.ecting rod assembly is ready and twe (2) nore should be ready for shipment 4/8/80. Possibly can_ send remaining two (2) connecting rods by 4/8/80. 4/09/80; Called.DeLaval as to the status of items shipped 4/3/80. Was ad-vised of the following;
, Nothing was shipped out or. 4/8/80.
> Having problems with . connecting rods. May have one ready for shipment 4/10/80. Remaining rods now scheduled for shipment on 4/15/80.
Seven (7) heads now. scheduled for shipment on-4/15 or 4/16. tr No status on remaining two (2) heads. No status on the four (4) er.huast manifold kits. i i d. O e a b r ! k-
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M/V COLUMBIA - REPATR PART STATUS 7/27/79; Ordered exhaust manifold conversion kits from DeLaval for installa-tion during routine repair period. 9/15/79; DeLaval entered above order with shipping date of 10/30/79. 10/05/79; Issued orders to Delaval for parts and labor to rebuild right and left bank camshaft assemblies on port and starboard main engines. Work to be accomplished during routine repair period. 11/29/79; M/V COLUMBIA taken out of service prematurely due to cracking of connecting rods in both main engines, 11/30/79; Advised DeLaval by TEXLEX of above problem and availability of the vessel for inspection in Seattle, 12/06/79; DeLaval representative arrived and looked at damaged parts removed from the engines thus far. Did not provide any answers or resolutions. 12/12/79; DeLaval advised that forgings required to fabricate replacements for the cracked connecting rod link boxes are due in Oakland on 1/11/80. 12/13/79; DeLaval Failure Analysis Engineer, arrived and spent two (2) days looking at damaged engine components. 12/19/79; Called DeLaval as to their recommendations resulting from the above inspection. Received little direction and requested that complete details be confirmed in writing. 12/21/79; DeLaval advised that the cracked connecting rods be sent to Oakland for rework. 1/11/30; DeLaval furnished control number for use in identifying the ship-ment of cracked connecting rods to Oakland for rebuilding. Requested and received control number for use in identifying the shipment of cracked cylinder heads, subsequently found. i 1/16/80; Sent letter to DeLaval requesting meeting in Seattle to discuss the engine problems and planned course of action. 1/18/80; Shipped four (4) cracked connecting rod assemblies to Oakland for rework. Shipped eight (8) cracked cylinder heads to Oakland for rework. One of these heads was the improved head we were testing for DeLaval. 1/21/80; 1ssued orders to DeLaval for repair of the cracked cylinder heads and connecting rods. (1)
l M/V COLUMBIA - REPNIR PdRT STATUS - (CONT'D) 1/23/80;; DeLaval agreed to a meeting but suggested it be held in Oakland at their facility on.1/31/80.' 1/31/80; Meeting in Oakland at:DeLaval facility. Discussed past and present'
~
engine problems and jointly inspected the cracked rods: and-cylinder heads . shipped down 'to them for repair. Probabl .e causes of the ' rod failures were discussed. However, no real resolution of past or present continuing problems were offereo. 2/07/80; .DeLaval representative visited the M/V COLUMBIA per our request be-cause.of the number of defective connecting rod bolts found and the-heavy fretting noted in the ~ link rod bushing bores, re - sulting from inspection areas suggested by DeLaval during the 1/31/80 meeting in Oakland.
-2/22/80; Sent letter to DeLaval cancelling the orders' placed on 10/5/79', for parts and labor to rebuild the camshafts on the port and star-board main engines. This was deemed necessary because budgetr ed funds were required to cover cost of repairs' to cracked rods and cylinder heads. Additionally the unplanned necessity to tear both engines down again, did not permit sufficient '
time to remove the camshafts as originally planned. It is hoped that the existing camshafts will last the four months planned operation. The order will have to be reinstated after-July 1,1980, (FY 1981 funds)- for accompiishment .after the: four months planned operation. 2/27/80; Advised DeLaval that one more connecting rod and two more cylinder heads were being shipped to Oakland for rework. DeLaval advised that first four rods wquid be ready for shipment iri 5 to 6/ weeks (approximately April 4). That four (4)cof the eight (8) heads sent down have been inspected. When' the re-mainder have been looked at, they would advise us of the .re-pair required. We had already advised them of the problem and each head had been so marked prior to shipment. They'were so informed and displeasure expressed in that little had been accomplished thus far even though the heads had been in their possession for a month. DeLaval additionally advised that the exhaust manifold kits would be ready .for shipment in three (3) weeks, (end.of March) and [ that three (3) link rod bushings can be shipped out this week l with the remaining seven (7) bushings in about a month (end j of March). l 2/29/80; Sent letter to DeLaval concerning macceptable time frame regardina , part status and shipments. No reply to date. . . i 3/11/80; Called Mr. Martin', at DeLaval, concerning part status. Was ad-vised the following; l (2) L l .
M/V COLUMBIA - REPAIR PART STATUS - (CONT'D) Will ship seven (7) heads on 3/25/80 Will ship remaining heads on 3/31/80 Will ship four (4) manifold kits on 3/31/80 Will ship seven (7) link rod bushings on 3/31/80 Will ship the connecting rods on 4/15/80 3/24/80; Sent letter to DeLaval concerning engine deficiencies and problems with request for planned action. No reply to date. 4/02/80; Called DeLaval for part status and was advised the following: Seven (.7) bushings were shipped on 325/80. The four (4) exhaust manifold kits should be shipped on 4/8/80. The cylinder heads should be shipped 4/8/80. One connecting rod assembly is ready and two (2) more should be ready for shipment 4/8/80. Possibly can send remaining two (2) connecting rods by 4/8/80. 4/09/80; Called DeLaval as to the status of items shipped 4/8/80. Was ad-vised of the following; Nothing was shipped out on 4/8/80. Having problems with connecting rods. May have one ready for shipment 4/10/80. Remaining rods now scheduled for shipment on 4/15/80. Seven (7) heads now scheduled for shipment on 4/15 or 4/16/80. No status on remaining two (2) heads. No status on the four (4) exhaust manifold kits. (3)
M/V COLUMBTA - REPATR PART STATUS.- (CONT'D) 4/11/80; DeLaval advised that two (2) of the'four exhaust manifold kits would be ready to air ship out today. The remaining two (2) would be. ready on 4/14/80. It was requested that shipping data be passed so we could follow it up in Seattle. 4/14/80; Called DeLaval requesting shipping data concerning the two (2) exhaust manifold kits that were to be air freighted Friday, 4/11/80. Was advised that the manifolds did not make it out on 4/11/80 and plan to ship all four manifold kits out today. They would call back 'today and advise shipping data. 4/15/80; Called DeLaval again requesting shipping data for the four (4) ex-paust manifold kits promised out yesterday, 4/14/80. Was
; advised that none have been received by them as yet for in-
!spection prior to crating and shipping. Might be able to f get them out by 4/17/80.
1 They advised that five (5) of the nine (9) cylinder heads [ sent down for rework are ready for shipment. It was request-
/ ed that they ship them by~ motor freight since these are the last items needed for engine reassembly.
[ They advised that only one (1) of the five (5) connecting rods l is ready. That they have had trouble finish machining the y other assemblies wherein the bearing bores came out eccentric.
~_ They are now attempting to re-machine the bores to accept s .030" oversize bearing. .
It was requested that they review the entire part situation and call back at 2:00pm this date with the latest status report. , DeLaval called at 2:30 pm and advised that all four (4) exhaust mani-fold kits should get out by tomorrow morning via air. Should have more data on the rods and heads this Friday (4/18/80). 4/16/80; DeLaval called and advised that all four exhaust manifold conversion kits were being shipped out this morning. Picked up by Profit by A.e and to be air shipped on United A/L Flight #2874, A/B
#771427.95, weight 853/lbs, due to arrive, Seattle, at approx-imately 1250/ hours.
Called United at 1330/ hours and they advised that shipment listed on manifest and they would deliver at 0830 tomorrow morning 4/18/80 via Profit by Air. 4/17/80; Called United at 0930 requesting Status of shipment. Was advised that shipment did not make the flight although listed on mani-fest. Shipment at airport in California and will get it on next flight to Seattle. Don't know why it was not on originally (4)
.M/V CCLUMBIA - REPAIR PART STATUS - (CONT'D) fl ight. Will advise status when known.
Profit by air advised that shipment due in Seattle at 2330 this date. Will de. liver tomorrow morning at 0830. 4/18/80;- Profit by Air-delivered the exhaust manifold conversion kits at 0900. Kits immediately transferred to vessel for inspection. Minor changes in fabrication / welding details were noted and water outlet connections not i~nstalled or provided. Will accomplish on board. Noted interior of exhaust gas outlet flanges to have several deep cuts resulting from flame cutting of the center holes. Must weld up the cuts or grooves and then grind inside surface smooth to prevent further deterioration by passage of hot exhaust gases. Condition is result of poor workmanship and lack of quality control / adequate shop inspec-tion. 4/21/30 Started making first cuts on stbd engine inboard exhaust manifold. 4/22/80 Removed front section at 1300 this date. Extreme difficulty in completing last cuts due to deformation of interior manifold pipe. Heavy locked in stresses. Interior pipe is one inch out of round and must find someway to return same to original shape or we cannot veld new sections to it. Also, examination of interior portion of removed head plate revealed major fractures in the weldments attaching support sleeves to the head plate. If this should again occur on the new head plates, water would leak out of the manifold and pass into the turbochargers, and require engine shut down. Since this is a real possibility, may pot modify the port engine manifold at this time to assure that we will have one engine to bring the vessel into port. Will have to jury rig the port engine exhaust system to make it functional for a few more months, pending evaluation of the stbd engine manifold modifications. 4/28/80 Completed fitting and welding of stbd main engine exhaust manifold end plate internal pipe - Tested to satisfaction. 4/29/80 Completed external pipe fitting and welding of stbd main engine exhaust manifold headplate. Received shipment of cylinder heads from DeLaval after repairs. Found valve seats not concentric with guides and requires approx-imately six (6) man / hrs per head to correct. 5/1/80 Installed stbd main engine after coolers and turbochargers to permit refitting of the exhaust elbows (16/ea. per engine). 5/6/80 Completed refitting of exhuast elbows on stbd main engine. 5/9/80 Balance of connecting rods and oversize bearing shells received this (5)
6 i M/V COLUMBTA - REPATR PART STM US - (CONT'D) PM via air freight. 5/12/80 The two (2) conne:';ing rods received 5/9/80 do not have ABS approvals. One of the first three rods has a +20" stamping on the heel of the link rod. Called DeLaval as to the lack of ABS appro-vals, the +20" stamping and also any marking indicating which rods have been machined for the .030" oversize bearings. Earl Shaw, of DeLaval, ad. vised that the last two rods may have to be shipped back to the factory. They got out somehow without ABS approval. The +20" stamping indicates that the link rod bushing in the new link rod is .020" oversize. The oversize rods have a stamping 1 A-6868 on the heels. Found the stamping noted but don't understand why a new link rod box ends up with a .020" oversize bushing. We are losing what standardization in parts we had. Called Bert Durie of DeLaval concerning the need to ship the two rods back to Oak-land. If the work had been followed by the inspector in the shop, possibly all that was required would be a final inspection and then approval stamping. Bert Durie called back and advised that the ABS inspector will come up to Seattle and complete inspection. That we could install the rods as is pending his arrival . Bert Durie called back again and advised that possibly Seattle ABS Office would inspect and approve the rods, but needed data stamped on heel of master and link rods ASAP. Obtained data and phoned to Bert Durie. Seems strange that DeLaval did not have record of rods prior to delivery. I requested that De-Laval expedite shipment of link rod hushing (standard size) to us. Local DeLaval representative, Dave Thompson, dropped by Seattle office and indicated that Mr. Martini has been unable to reply to my letter of March 24, 1980. Suggested meeting in Oakland, with Zbinden, Commissioner Ward and Director Eide. Indicated to Mr. Thompson that no purpose would be served unless problems noted in the letter were to be resolved. Suggested that if any such meeting were to be set up, we needed to know the topics to be discussed and that the meeting be held in Seattle or Juneau in lieu of Oakland. 5/13/80; Called DeLaval about the necessary link rod bushing, pins and piston "0" rings. Was advised that parts are to be shipped out today. 5/14/80; Called DeLaval bout cylinder head J-26 shipped to them on RMR-5731-62 for repair and return. Have heard nothing nor seen head re-turned. Where is it? DeLaval to check it out. Also requested shipping data on link rod bushing, pins and "o" rings. DeLaval advised parts shipped to day and passed on A/B#, (6)
M/V COLUMBTA - REPAIR PART STATUS i
'5/15/30;- Received shipment of link red bushing, pins and "0" rings. Found l one (1) newly received rod bolt rusted and with thread damage. Unfit for use.
Called DeLaval as to status of J-26 cylinder head. Ad-vised then that we need it or one on consignment to serve
'as required spare.
5/16/80; Called Mr. Watson of ARS Seattle about the rod inspection proposed ' by DeLaval. He advised he would do this morning. We expect to have all rods and pistons reinstalled by end of the day, Monday May 19, 1980 and all heads reinstalled by Tuesday night May 20, 1980. Mr. Watson of ABS arrived and accepted the two connecting rods as ABS approved. Mr. Dave Thompson of DeLaval stopped by and visited COLUMBIA. He again brought up the subject of the meeting Mr. Martini desired and previously proposed on May 12, 1980. , He was again advised that the agenda to be covered should be provided prior to establishing any such meeting. That unless DeLaval had permanent solutions to the existing problem, any meeting would in effect be a waste of everyones time. 5/27/80; Engine reassembly delayed due to need to grind valve seats on re-built cylinder heads to make same concentric with valve guides. Two cylinder heads still not returned. One additional cylin-der head (J-26), returned to DeLaval at beginning of 1979 season, still has not been located by DeLaval . Local engine representative made aware of long term problem wherein valve seats are not concentric with valve guides. Because J-26 head cannot be located, ordered new cylinder head for ABS required on board spare. Head received (K-40). Notec that this head has thicker fire deck than previously furnished heads. DeLaval spares section advised that they will ser.d letter concerning numbers of parts used on this new head since they differ from the rest. The final two cylinder heads were received and it appears that attempts were made to resolve the concentricity problems be-tween the valve seats and guides. Their efforts caused another
- problem wherein a lip was left on the upper portion of the ex-haust valve seats which prevented the valve from seating.
Crew had to manually grind same away before valves could be lapped in. Heads effected were A-2 and A-27. It was noted that we have two cylinder heads with the same A-2 serial number. Unable to install lockwire in one new 14" rod cap screw. Re-leased rod bolts and recoved ih" rod cap screw for examination. Found. lockwire holes not drilled thru. Appears to have broken (7)
M/V COLUM81A - REPATR PART STATUS drill bit in the center preventing use of either ifre passage. Also noted that wire holes on the bolt were not chamfered to prevent cutting of wire. Called DeLaval to air ship out replacement bolt ASAP. Also found 17/8" connecting rod bolt on another rebuilt rod assembly to have thinner than normal nut. With cotter key inserted, it is above the end of the nut. Exchanged with one of our original used nuts. 5/29/80; Filled Starboard main engine jacket water system. Found leaks on outer plate of both newly installed exhaust manifold head pl ates. 5/30/80; Pulled exhaust elbows from both exhaust manifold head plates on SME. Ground out and rewelded cracks. Refilled jacket water-system and found no further leaks. 6/2/80; Called DeLaval about status of 11" rod cap screw. Was advised that it 3 didn't get shipped out. They will do so today. The defective bolt was finally cleared of a portion of the apparent broken drill bit pennitting use of one of the two drilled lock wire passages. The holes were relieved to prevent cutting of the lockwire and the bolt installed. Conducted dock trials---satisfactory on both engines. 6/3/80; COLUMBIA departed on sea trials at 0900 and returned at approximately 1830. Trials satisfactory. However, noted that expansion-tank sight glass on SME revealed vapor passage. This assumed to be steam vapor generated by new exhaust manifold head plates. Inspection of the new head plates prior to installa-tion suggested that this was a possibility. Still trying to track down the missing (J-26) cylinder head. Requested copy of signed delivery ticket from transport company to prove that head in fact did get delivered to De-Laval in Oakland. It should be noted that six (6) months have past since the original engine failure. The delay in getting the vessel back l on li~ne is due to the inability of DeLaval to furnish repair parts. (8) m~ ~ . - V
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DEPARTMENT OF TRANSPORTATION GD l'UBLIC FACILITIES June 17,1980 Transamerica DeLaval, Inc. Engine & Compressor Division 550 - 85th Avenue Oakland, California 94621 SUBJ: M/V COLUMBIA Cylin' der Head J-26 ATTN: Bert Durie
Dear Mr. Durie:
On May 25,1979, shortly after overhaul of subject vessel's main engines and resumption of service, cylinder head J-26 was removed du'e tc indications of internal water leakage. Subsequent testing revaaled the presence of a leak in a crack in the exhaust passage area. .This cylinder head had Just been repaired (hard valve seat facing renewed) by DeLaval. The crack may have resulted from associated ytelding stresses. RMR 5731-62 was furnished for repair and return of the J-26 cylinder head. The cylinder head was shipped to your facility on July 5,1979 via ETMF on Pro #01-071895-6. Included in the same shipment was a spare piston which was being forwarded. for modification on RMR 86J3. The spare piston was modified, returned and. received by us on November 2,1979. The J-26 cylir. der head has not been returred to date. Efforts by your Linda Black in locating the missing cylinder head, over the past several months, have been unsuccessful . Since the cylinder head and the piston were shipped together, and the piston known to have been received, modified and returned to us, we assume that ,the cylinder head J-26 was a' Iso received. To confirm this, E*MF was contacted and a copy of the delivery tic' et < requested. A microfilm print of the delivery ticket in question is attached for your information. It does indicate that' the shipment was delivered to your facility and received for. Accordingly, it appears that Transamerica DeLaval owes one (1) ABS approved cylinder head. It should be noted that as a result of the apparent loss of the J-26 cylinder head, our only spare, we had to order another cylinder head to be carried as the required ABS' spare prior to resumption of service by M/V COLUMBIA on June 6,1980. This cylinder head was ordered on 0.0. #589268 and was received cn board on May 27, 1980 and is serial number K-40. L
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- . -l i' .. ' Transamerica DeLaval, Inc. e Engine &' Compressor Division June 17,1980 1
.Z i
- ATTft: .Bert Durie
- t J
I Your action in resolving the matter of the apparently lost J-26
-cylinder head is requested.
Sincerely, _/{ g ,,f b M ~ , / ~~ i MaxjE. Zbinden ' i- P'o' c ject Engineer
- Pier 48 Seattle, Washington 9810a 4
i Encl: Copy of ETMF delivery ticket Pro #01-071895-6 F cc: Jeoff Berggren/ Parts Department /Transamerica Celaval' Dave Thompson / District Manager /Transamerica DeLaval d 1 i ~ r 4 t l 6 I l 1 i l i ,$ 4 l 2 f5 L . . . . , - . .. . _ . . - -.-- -.- - - - . . , _ - - . - . . . . . . . - . - . . . - . - - . - , _ . - -
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Meeting between Transamerica Delaval and State of Alaska or.
. September 4,1980 at Pier 48, Seattle, Washington.
? Personnel in attendance: Delaval: Clint Mathews, Dave Thcapson and Alan Barich
- - Alaska
- Ron Lind, J. Eide, H. Mcdonald and'M. Zbinden 1 Replacement for lost J-26 cylinder head due to be shipped p from factory on September 12, 1980 - as per telex to Dave L Thompson from Bert Durie of Delaval.
l
- 2. It was agreed that no problems presently exist with respect to outstanding invoices, etc.
- 3. Camshafts Time frame for removal of M/V COLUMBIA from service presently l December, 1980 l We will attempt to ship to Oakland by Xmas.
i Delaval will return by 1-20-81 We will inspect camshafts on 18/19 September.1980 to ascertain condition of lobes, rollers,iand followers. ' Alaska to get order ,out for shop work to rebuild camshafts- / most economical means. ' Alaska to check with Delaval Parts Section as to whether cam-shaft bearings and followers are in stock. If not, must order or cause Delaval to stock. Questioned Delaval as to whether M/V COLUMBIA cams are same l as current production engines. Not really clarified - but suspect d not. Point made due to necessity for us to order some to assum.e availability even though we may not need them all .
- 4. Cylinder Heads, i
i- Delaval discussed core problems on fire deck in past. Our new head deck is thicker because condition corrected. Not same j as original core shift probl5m. Addition of " posts" to existing cylinder heads (those apparently effected by the core problem resulting in thin castings sections around the outer edge of the cylinder heads) should resolve warpage problem at 3 and 9 o' clock positions and burn out of fire rings. Delaval now stress relieves all heads after original machining and af ter valve seat rework. Any heads we had reworked last year, should have had stress relief. Heads so marked with SR,2 _ . - . . . . . - . . _ . , _ . . . , . . . . _ _ . . . . . , . _ _ _ , , . . . . _ . . - . , , , _ . _ _ , , . _ , . _ , _ . , , _ - , . , _ . ~ ,
Delaval indicated that design is fixed until proven deficient. Based on instrumentation of heads and inspection of sections.
- 5. Connectina Rod Assembiies Delaval advised that in house and independent studies revealed that current rod design adequate with change in bolt si:e and torque as used in the five reworked COLUMBIA rods.
Delaval advised that connecting rod shell cracking recently experienced on COLUMBIA could have resulted frcm bad bearing alloy makeup by their vendors. Delaval looking at different bearing materials. Delaval was questioned as to advisability of modifying the remaining COLUMBIA rods -in a like manner. Non-comi ttal .
- 6. Quality Control and Part Support Various problems discussed. Delaval advised that they are aware of the problems and are attempting to resolve same.
- 7. Pistons Delaval believes design is adequate. Was unfortunate that they goofed on modifications. Effected others besides COLUMSIA.
Discussed need for fourth compression ring - the one fitted in the groove at the joint between the 'iston crown and skirt. Non-committal and decision lef t to operacor, , Delaval apparently lookin'g at other piston designs.
- 8. Turbochargers Lack of adequate air except at near full load operation was discussed.
Delaval advised new using Delaval turbo in lieu of Elliot and B&B units. Advised of improved performance and increased fuel economy of about 37,. Lower firing pressures and exhaust temps. Requires use of pulse converter between exhaust manifolds and turbos. This is not same set up as proposed by Delaval last year wherin revised internals were to be installed in our existing Elliot turbos. Delaval recorrmended installation of water wash system as
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installed on. M/V GOTT. Reportedly kept engine pistons, turbos, etc., clean. (Note: M/V GOTT operates on heavy fuel . While installation maybe of value on heavy fuel operations, not deemed nece<sary on normally diesel fueled engines.}
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- 9. Procosals
.Delaval to get together various proposals for our consideration.
This could include derating existing engine, replacement er.gu es, etc. Tentatively agreed to meet again in Seattle on Septe.rber 30, 1980. Based on result of meeting
- 1. We should proceed with repairs to camshafts on both main engines.
Delaval Parts - $62,000 Delaval Labor - $40,000 Cam Follower -
$32,000 Est 155 K Cam bearings -
$18,000 Freight -
S 3,000
- 2. We should modify remaining connecting rods.
11 each 9 $12,000 including bearing, bol ts, etc. freight Es.u 135 K
- 3. Consider procurement of one engine set at new cylinder heads-Expected repair costs to : existing heads is approaching new replacemnt cost -
16 each 9 $16,000 Est 256 K includes gaskets, freight, etc. (Use removed heads to maintain other engine - repairing same as necessary)
- 4. Defer any acticn on installation of waterwash systems since it is not deemed necessary on normally functioning diesel fueled medium speed engine.
- 5. Obtain cost data on Delaval turbocharger package for future considera tion.
- Me: ting betwe:n Transamerica Delaval and State of Alaska on Sept- '
ember 30,1980, at Pier 48, Seattle, Washington. Personnel in attendance: Delaval: Clint Mathews, Dave Thompson, Alan Barich and Jeoff Berg-gren Alaska: Ron Lind, J. Eide, H. Mcdonald and M. Zbinden Delaval provided a summary of items to be covered. Copy attached.
- 1. Camshafts: It was decided to procure four (4) new camshaft assemblies, two (2) per engine, at $23,000 each in lieu of re-conditioning the existing units. Reconditioning could cost approximately $32,000 each, depending upon damage sustained by inlet and exh. lobes during removal. Additionally, procurement of new assemblies would permit earlier removal of heads and rods.
The modification and timely return of the latter is hinged on our ability to get them to Oakland ASAP and initiation of im-mediate order so that Delaval can get the rod box forgings ordered and machining started ASAP. Mr. Eide to check on funding status, and decision will then be made as to whether cam lobe order already placed will be cancel-led and new assen.blies ordered or whether we shall add onto or issue separate D.0. to cover the balance of the costs.
- 2. Master Rods: It was decided to remove the eleven (11) rods from , .,
the engines and ship same to Oakland for modification. This to y, e include the lis" cap screws, new hardened washers, .030" 0/S 3i.to spare rod f;'nd" connecting rod shells and new link rod bushings. assembly will also be shipped down for modificationThe as above, ' Delaval agreed to machine the one previously modified rod to take the .030" 0/S connecting rod shells at no cost. This would standardize the rod and bearing assemblies on both engines. We must get the rods down to Delaval ASAP and need only send the Master halfs with bolts for the original eleven (11). We will also send them by engine sets and want them returned in same fashion to p'ermit closing up of one engine ASAP.
- 3. Water Wash System: Quotation furnished with cost $3,272.90 per engine---Simple installation but would require mods to each intake elbow, air and water supplies, etc. Not deemed necessary for diesel fueled engines and considered of low priority in relation to overall problems at this time.
- 4. Elliott to Delaval Turbocharger Conversion: Delaval furnished
, outline drawing of instal.lation on DMRV-16-4. Did not work up quotations since it would require engineering work up. Would do if interest expressed by the State.
y _ _ _ . _ _. _ _ . _ . _ . ~. . a State expressed interest in turbo conversion based on improved - fuel. efficiency and requested that -Delaval proceed with engi-neering work _up...We will make preliminary check as to inter- ! ferences using furnished drawing and advise them at findings... " Plan is to get set for installation next year...Mr. Eide indi-- cated that'we may get out order in March,1981. . (Project will require changeout of the four (4) engine mounted units plus
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- ABS required spare).
- 5. Scamatic L.O. Filter: Quotation furnished. Recommended for use in lieu of duplex full l flow filters as presently. installed...
Estimate $48,000 per ship set.. Does not. attack source of problem. Believe Delaval now looking at benefits of more adequate lube oil filtration and purification...No doubt'leari.ed from U.S. Steel Great I.akes Fleet. We should look into for future consideration along with other L.0. associated problems with C/E. 2
- 6. Lube Oil By-Pass Filter & Pumps: Quotation furnished utilized 3
by M/V GOTT and circulates a portion of the oil thru a 5 micron + fil ter. . . Cost est. $23,000 per ship set. Comment same as abov'e. Delaval further reconnended shifting'a F.0. purifier to L.0. I service...and reducing output of existing unit... Again, should discuss with C/E and evaluate overall lube oil system.
- 7. Cylinder Heads: Proposal consisted of 4 sections, A-thru D, i as follows; 1 A_. Mod cylinder heads - Side posts only '
i
@ $2000 per head. Would include S/R and pickling.
, B_. Same ar. A but include valve seat rework, remachine combus-t tion face, reassemble etc. @ $5000.00 per head. C. Same as B but excludes reassembly @ $3000 per head. i li. New heads, -complete @ $14,757.00 per head. Item A-is a jury rig fix or a fix of sorts- to correct an initial casting problem...Have no knowledge of its effectiveness nor ex-pected life span. 4 Item B-Includes above suspect repair action and covers cost of reassembly nonnally accomplished by crew... I Item C-Includes above suspect repair action. Item D-Provides for new heads which have latest casting improve-
- ment benefits, are S/R and pickled.
, Latter item is suggested as.only proper way to proceed. We have several leaking heads now and many have been repeatedly reworked.
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- During the past years, many of our original heads were exchanged
- during rework by Delaval for other used heads. We have no idea of the history of many of the existing heads. Would expect we would have to start replacing. heads soon. .
Plan to only procure sixteen (16) heads to outfit one engine. The
~,.,__,_..--.._-.-.-_._-,.,.I.,_,..._._,_.,.-...,__-.._
best of the renaining _ heads will be shifted to th5 other engine and provide us with spares. The junkers can be sent to Delaval for??? credit of sorts. .This action will permit us to evaluate the better quality heads.
- 8. Shrouded Fuel Injection ~ Lines: Quotation furnished $15,400 per engine. . . Safety item. . .to be discussed with C/E.
NOTES Interesting that cost for piston rework has ' dropped. Cost of rod bearing shells also lower. Many possible reasons. Will check with Delaval on availability of cam-shaft bearings, fol-lowers, etc. Warranty of new parts one year from delivery. Delaval to provide RMR# for incorrect cylinder assembly stud...To cover return and exchange for correct part at N/C. Delaval to provide status report concerning progress on various re-pair' items, j l l l l 1
a
SUMMARY
-1. Camshaft .
A A. Save old shaft and issue purchase order for new lobes o B. Cut up cid shaft ,to save as many lobes as possible.
.C. New camshaft assembly D. New tappet assembly
- 2. Master rods - mate (12) master rods with new boxes to incluc bottle bolts.
- 3. Water wash system - quotation
- 4. Elliott to Delaval Turbocharger conversion - presentation of envelope
- 5. Scamatic L.O. filter: - quotation
- 6. L.O. by-pass filter pump and larger L.O. centrifuge
- 7. Cylinder head - quotations A. Rework to include side posts B. Rework - complete
'C. Rework - s'tuds and guides only D. New cylinder heads 8 '. Shrouded fuel injection lines - quotation 3
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CYL1;;Di:n !! LAD 3 N
/- /' / 7 A. Cylinder !! cad Rework - Side Posts Only The price to rework used cylinder head assemblies oc ou. niant
$2,000.00 per cylinder head. The rework includes:
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- 1. Disassemble
- 2. Clean
- 3. Hydrostatic Test 4 P.ill slot for side post
.5. Weld post and side plates' d
- 6. Re?.achine cor.bustion face
- 7. Stress Relieve i
- 8. Mater test l
l t
- 9. Pickle
- 10. Deburr and clean .
- 11. ilydrostatic Tes:
4
- 12. Reassembly
- 13. Final inspection See T. tem B. for any extra uor!: such as talve seats, etc.
Deli'rery 5 weeks after receipt of cylinder heads. I The above is based on a quantity of 16 cylinder heads. 1
- 3. Cylinder Head Rework - Complete i
The price to rework.used cylinder head assemblies at our lant
$5,000.00 per cylinder head The rework includes:
l 1. Disasse-ble
- 2. Clean r
l 3. Hydrostatic Test
- 4. Inspection
--.., -,,_-:..-._ - _ _ . + , . + _ . - _ , - ,
'Ittm 7.
B. Cylinder Head Revork - Cocolete (continued)
- 5. Mill slot for side. pos:
- 6. Weld post and side plates
- 7. Remove exhaust guides
- 8. Drill fuel nozzle bore
- 9. Drill welded plut
- 10. Excavate valve seats 11 . Water test
- 12. Counterbore fuel nozzle
- 13. Weld plugs and seats
- 14. Machine seats for hard face
- 15. Preheat and weld seats 4
- 16. Stress relieve
- 17. Remachine shroud side
- 18. Remachine combustion face
- 19. Machine periphery
- 20. Machine exhaust and intake bores
- 21. Machine seats and grammet bores
- 22. Inspection - die check seats
- 23. Finish fuel nozzle bore 24 Drill and cap dummy plug
- 25. Deburr and clean
- 26. Ilydrostatic Test
- 27. Reassembly - includes valves, springs, wedges, studs & Auides, etc.
- 23. Final inspection Delivery after receipt of cylinder heads is 7 waeks.
The above is based on a quantity of 16 cylinder heads.
k ' Itim 7 i C. -Cvlindar llead Reewrk - Studs & Guides Price to rework used cylinder head assemblies at our plant ~
$3,000.00 per head. The rework includes all items listed in Item B cxcept ite:n 27. Reassembly includes only studs and guides. Delivery 7 weeks after receipt of cylinder heads.
I D. NEW CYLINDER HEADS The price of (1) 1A-6241-ABS cylinder head S14,757.00. Delivery on a quantity of 16 is 10 weeks'after' receipt of order. l i i 3 i i i ) i I 1 i 4 ! l i . e n . . .--. ,. , , - - . . , , - ,e--~.,,. -.---,,...,,..,,--,,.,..n . , ,r
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f~s q; \~3 Q . 4 I?\? $ $:lP 5Ll$\5b Aik l l " "~ = ~ # l l DEPARTMENT OF TR ANSPORTATION AND PUBLIC FACILirlES , MAINTENANCEAND OPERATICM' ! July 25, 1980 Donald McL Davidson Fe ~nson & Burdell 4 1710 'eoples National, Bank Building Seattle, Washington 98171
Subject:
Alaska --- Lockheed; M/V COLUMBIA
Dear Mr. Davidson:
1 This is to update you relative to the items noted' in my letur i of January 24, 1979, pertaining to the provisions contained in Section 3 of the June 19, 1978 agreeinent between the State of Alaska and Lockheed Shipbuilding & Construction Company. The status todate is as follows , . referring to the sub-paragraphs as numbered in the agreement; 3 (a) Turbochargers l (1) All four installed turbochargers have operated in excess of 4000 hours without breakage of a nozzle ring since the turbo manufacturer revised the nozzle ring bolting configura tion. (2) All four installed turbochargers have operated in excess of 4,000 hours without any abnormal buildup of deposits requiring cleaning and rebalancing. l (3) Operation at low engine RPM, with respect t'o oil seal leakage, has proven satisfactory af ter installation by Delaval of the external air sealing system. The turbocharger deficiencies have, th'erefore, been resolved.
- I 3 (b) g/linder Heads 1
The engine cylinder head: did not operate satisfactorily during the 1978 season nor to date. The heads were subsequently reconditioned at Delaval's Oakland tacility. during the 1978-1979 engine overhaul and were c.tinstallet. A cylinder head with beefed up side walls was turnisned 4 by Delaval for operational evaluations and wu installed at the same time. Whether this cylinder head w? Of
Donald McL Davidson July 25, 1980 Ferguson & Burdell page 2 "The improved manufacture and design" was not indicated. Snortl y af ter the vessel resumed operation during the 1979 season, one of the reconditioned heads cracked in the exhaust passage and was returned to Delaval for rework. All cylinder heads were again removed during the 1979-80 engine overhaul. Ten of the thirty-two cylinder heads were found cracked to varying degrees, including .the head undergoing oper-ational evaluation after 4500 hours operation. The cylinder head which cracked shortly af ter commencement of the 1979 season was apparently lost at the Delaval.. repair facility. A new replacement cylinder head was procured by the State, to proved the necessary ABS, onboard spare, pending resolution of the missing head. This cylinder head was found to have a much thicker fire deck and utilizes different intake valve guides and seals and is fitted with valve rotators. This head was installed by the State for evaluation. It is not known whether this head is of "The improved manufacture and design." The matter of the lost cylinder head has been seperately resolved between the State and Delaval . 3 (c) Fire Rings Problem remains and is associated with the cylinder head warpage proble.ns. It could be that the fire rings would be satisfactory if it were not for the head problems. l A neeting has been set up with Delaval on August 23, 1980 to discuss various engine problem areas and when resolution can be expected. The meeting will cover the cylinder heads amorg cther items and may shed some light on the continuing problem. l Concerning the Memo of Understanding agreed to on January 5,1978, and in particular Section 5 concerning th.e vessel's prop 'iers, the following has occured todate. The propeller stucy w/s received on September 19, 1979. Unfortunately, major p.obisus on M/V COLUMBIA developed at that time, which required the roll attention and resources for over six months of those personrel who would otherwise review the propeller report. The report and past data is presently being reviewed and evaluated . by tae State. It is expected that some position should te forth-coming the latter part of August 1980 or early September The above infonnation should be of help should you feel that LSCC should be updated on the matter. Sincerely, , '
?>.
Max Zbinden
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ALASKA 8f h /j 'O I Robert Ward DATE 11/6/80 Cormi ssioner DOT t. PF '** Juneau, Alaska o 99811 j,, y rettaene no h FevJip//f'b'nden!V #
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- t. sus;ect M/V COLUMBIA: Main engine status Project 4ngineer report.
Pier 48" Seattle Washington 98104 The M/V COLUMBIA,1978 season was cut short due to heavy main engine lube oil contamination, with water and solids (carbon / soot), and lube oil filters life reduction to approximatley 30/ hours per set. During the 1978-79 Columbia main engine overhaul, at approximately 17,000 total engine hours, the following major work was accomplished:
- 1. All cylinder liners were removed for shop honing by Delaval. Two of the 32 liners were beyond redemtion and were renewed.
- 2. All lower half main bearing shells were found badly worn and were in effect renewed by reversing the upper and lower halfs.
- 3. All connecting rod shells were found badly worn or othenvise unfit for further use and were renewed.
4 All the pistons were sent to Delaval for modification as per their latest SIM.
- 5. New ring sets were installed on all pistons and piston pin end caps re-rolled.
S. All cylinder heads were reconditioned and the major portion of them were sent to Delaval for reworking in the shop due to cracks and/or need to restore valve set hard facing.
- 7. Turbochargers were overhauled, cleaned and balance checked.
Operation during the 19.79 season initially revealed a reduction in lobe oil consumption and increased lube oil filter life. Approximately 2700/ hours af ter the 1978-79 overhaul, a rod bearing cracked and was renewed. Vessel operation continued for 1600 more hours at which time four (4) connecting rod assemblies were found cracked. Two each on the port and starboard engines. Other rod bearing shells were found cracked, and some were not related to an associated cracked rod assembly. Additionally, the lube oil filter life was again starting to drop. During the subsequent 1979-80 engine overhaul at approximately 22,000/ hours (4300 hours since the previous major overhaul) the following work wa: acccm-olished:
Memorandum. . . Cont'd. . . . . .M/V COLUMBI A. . . Main engina status report---Page (I v
- 1. All connecting rods, pistons and cylinder heads were removed for in-spection.
- 2. The four (4) cracked rod. assemblies were sent to Delaval for rework.
One additional rod assembly that had. damaged link rod box threads was also sent to Oakland for rework.
- 3. All heads were reconditioned, of which approxim.ately 12 were sent to Delaval for rework.
l 4. The watercooled exhaust manifo.ld end plates were installed on the SME.
- 5. All the steel link rod bushings were removed from the link rod boxes and new bronze bushings were installed.
- 6. The fourth compression ring on the majority of all pistons were damaged and so was the ring groove. The fourth ring was left off of approximately three (3) pistons that were inspected since_ a new ring could not be installed without some remcchining of the piston itself.
- 7. Vessel placed back into service on July 5, 1980, for a.three month period, July - August and September (peak traffic season).
During the 1980 season, the lube oil continued to become increasingly contaminated with carbon / soot and water. The lube oil filter life also began to drop rapidly. One cylinder block bolt cracked on the SME and was renewed. By the end of September 1980, the oil contamination problem was rapidly deteriorating. Operation of the wessel had meanwhile been programmed thru December 11, 1980. From an engineering point of view, this was an impossibility since the work accomplished during the prior repair period was only to get the vessel thru September. Operation con-tinued into October. The lube oil and filter problens became worse. Lube oil on both main engines was changed out the week of October 6. One cylinder head was changed out during the week of October 13, due to heavy external water leakage. Lube oil was again changed out on the starboard main engine during the week of October 20. Lube oil filter life down to 40/ hours and abnormal smoking noted around the engines and precipitators. Engine room bilges were detergent cleaned to reduce probability of fire should we experience a base explosion. Difficulty being experienced with maintaining crankcase vacuum. Vacuum fluctuating. During lite-off for departure from Seattle, on October 24, crew noted difficulty in starting SME. Vacuum fluctuating badly during the evening and heavy smoke dis-charging.from precipitators. Smoke situation becoming worse and causing eye burn. Vacuum. dropped to one tenth of an inch and the bilge; filled with smoke the morning of October 25, 1980, and SME secured. Continued operation could have resulted in a possible crankcase explosion due to the heavy blowby. Vessel returned to Seattle, on October. 30, 1980, on o I L
MEMORANDUM. . . Cont'd. . . . .M/V COLUMBI A. . . Main engine status report---Page III port main engine and entered repair status after approximately 2300/ hours operation during the 1980 season and approximately 24,000/ hours total since installation. The results of the current engine tear down,- findings and work accomplished will be subject of further correspondence. CC: Ron Linde/ Deputy Commissioner James Eide/ Director A.H. Mcdonald / Port Engineer Chief Engineer /M/V COLUMBI A o
=
c ALASKA. // F F Robert Ward om December 10, 1980 Conmissioner
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Juneau, Alaska 99811
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! om Max-Zbindgd SUBJECT M/V COLUMBIA: Main Engine Status j Assistant Por, Engineer . Report #2 Pier 48 i Seattle, Washington 98104 - 1 As of December 5, 1980, the following has been accomplished on subject vessel.
- 1. All cylinder heads have been removed.from both main engines and dis-assembled. The bare heads are bcing cleaned, pressure tested for leaks, dye checked for cracks and checked for warpage.
- 2. All connecting rods were. removed from both main engines and disassem-bled. Those requiring modification have been shipped to Delaval with j a return date of late December,1980. New connecting red cap screws I
and washers have been ordered for the five rods reworked last year be-cause the increased. torque caused the mating surfaces to become gal-led. Delaval is now using hardened steel washers to try to eleminate the problem. One of the new connecting rod bearing shells, . installed-3 in a rod reworked last year, was found cracked.
- 3. All. pistons were removed from both main engines. Heavy wear noted at side thrust areas. Heavy hard carbon build up in area of compression rings. Instructions received from Delaval en December 5,1980, re-quire that pistons be cleaned of all carbon and stripped and then 1
shipped to Delaval for rework of the 4th ring groove area. This re-work required due to design / machine error by them during original piston modifications made in conjunction with the 78-79 overhaul. Some of the pistoas will require replating or possibly renewal due to the effect of the heavy blow by and scoring sustained this last season. It.is expected that all pistons will be shipped to Delaval by December 19, 1980, with a return date of mid February,1981.
- 4. The cylinder liners on both main engine's have been inspected and measured. Several liners will have to be renewed due to the broach-ing effect caused by the blow by. The lin-ars are heavily coated with varnish and show signs of excessive piston side thrust. Approx-imately 19 of the 32 liners exceed manufacturers published out of round limits. It is understood that Delaval is to provide written instructions modifying these limits to increase the out of round-i ness permitted and also reduce the maximum allowable liner diameter.
Corrective action with respect to this phase is pending receipt of the above information. Approximately 21 of the 32 liners have lost their crush. The details and possible causes are involved but is a new phencmena. Repair action would require. machining of the engine block.in way of each
MEMORANDUM. . . Cont'd. . . .M/V COLUStBI A. . . Main Engine Status Report #2. . .Page il effected liner landing area and the insertion of a shim to restore the crush which restrains the liner in position vertically. Simi-lar action was taken on one cylinder two years ago, but for a dif-- ferent reason. In that case the liner landing area was found not parallel with the block surface. All liners were removed from the Port main engine to permit inspec-tion of the block bore in view of the loss of crush problem. It has been found that the upper bore area, which positions the liners horizontally, is worn egg shaped and are oversize. Another new phenomena. We presently have no idea of how the condition can be corrected. The fact that the bores are egg shaped will make it difficult to properly accomplish the machining required to restore the liner crush noted abcve. Delaval has been made aware of the situation and are apparently working on same. Removal of the Star-board main engine liners for similar inspection is pending.
- 5. All four (4) main engine turbochargers have been removed. Delaval has flip-flopped several times between suggestions in using either their turbo or the modified Elliott unit. As it presently stands, the Elliott unit has never been built todate. Therefore no opera-ting data exists and we have enough experiments in the_ works. The Delaval unit is expensive and would require much engineering and shipboard modifications prior to installation. Even if funds would be made available, time is not. We are therefore ' planning to stay with the existing units. They will be cleaned, balanced and re-built as necessary.
- 6. All fuel injectors have been removed for overhaul . Action is pent ing Delaval's recommendation in changing the tips.
- 7. All fuel pumps have been removed. Those from the Starboard main engine only will be overhauled. This will give us a base point on at least one engine on which we will conduct an engine analysis after vessels return to service.
- 8. The Port main engine exhaust manifolds have been disconnected and I are positioned to permit installation of the water cooled head plat:;.
Work on this is expected to start next week.
- 9. We have ordered and expect to install the cylinder water-wash system l that Delaval proposed during one of our September meeting in Seattle.
l- We had initially decided not to use it, however, the accumulations, l of carbon in the combustion area, noted this tear-dc..n, suggests that we not wait. If we can rid the engine of some of the carbon before it does damage, the small cost would be worth it. It will not eliminate the problem. It will hopefully eliminate some of the effects.
- 10. The 16 new cylinder heads previously ordered have been received and will be installed on the Starboard main engine.
- 11. Currently are checking the cause of excessive Port main engine crank-shaft destortion.
l MEMORAfiDUM... Cont'd...M/V COLUMBIA... Main Engine Sta2us Report 02...Page IiI It appears we are turning up new problems faster than we can provide permanent fixes for the old ones. Our major concern at this time is with the block pro-blems noted in section 4 above. We are awaiting input from Delaval in this regard. Just what effect, if any, the corrective action will have on the pro-grammed sailing date is unknown at this time. We do know that a significant deterioration of the engine has occurred over the last 7600/ hours of operation. Whether it is related to the piston modifi-cations, made by Celaval at that time, is only conjecture at this point. Attached is a copy of the only Delaval correspondence received todate. The first two paragraphs are nice. The third paragraph basically states that we are operating the engine lightly loaded and that is why we have low manifold pressure, etc. We did in fact increase.the propeller pitch this last season in an attempt to increase the manifold pressure. Additional.ly, preliminary review indicate a variance between the curves presented and the curves we were originally provided. The fourth paragraph justifies the use and per-formance of the turbochargers we have. Meanwhile we do not have the manifold pressure we should have unless we are at full power or nearly so. We have repeatedly so advised Delaval that the turbochargers are inadequate for mid . range performance. The following action is being taken with respect to the number paragraphs of the letter:
- 1. Since we must install new piston rings anyway, we are planning to utilize the proposed new rings.
- 2. Since the pistons will be set up for machining anyway, the added cost of reducing the piston crown diameter,is deemed warranted and is planned for accomplishment. It will not cure the basic problem but could lesson the effects between engine overhauls.
- 3. As indicated earlier, we have procured the cylinder water wash equipment. The washing of the turbochargers is a new item since our last meeting with Delaval in September,1980. We do not intend to wash the turbochargers at this time.
4 We do not feel that the added cost of this system is justified at this time with so many other problems facing us. It will make the valve stems and gui' des last longer and is used on most other engines of this type. Such an installation will not resolve the basic engine problems.
- 5. We initially had 1500 nozzles. These were later changed to 1400 nozzles as recommended by Celaval to keep the fuel spray from wash-ing down the liner walls. Inspection of the piston crowns shows that the 1400 nozzle spray pattern was still a bit wide. Hence the latest recommendation for 1350 nozzles. We are presently awaiting cost and availablility data on the new nozzles before making any decision.
1 1
ggeRAtlDUM. . . Cont'd. . .M/V COLUMBI A. . . Main Engine Status Report #2. . .Page IV
- 6. If the installed turbos would function properly if we loaded up the engines, per their comments, why should we install the C-17 Delaval turbo? The point is toot in any case. since we do not have the time.
- 7. The engine lube oil filtration system could be improved upon and should be done if we ever can obtain sustained engine operation.
The installed system is adequate when the. engines are first over-hauled. The major source of contamination at that time is the carbon which passes up the cylinder head valve guides and is then flushed into the crankcase lube oil. This abnormal condition has existed throughout the life of the engines and a variety of fixes provided by Delaval have had little effect thus far. It is when the engines start to suffer from piston blow-by, that the installed system becomes overloaded. This requires continuous oil purifica-tion with 'the centrifuge and results in increasingly short filter element life. We have been using the filter life cyle as a tool, although somewhat crude, to serve as an engine condition indicator. To improve the filtration system at this time would change the engine condition indicator. It would not improve the internal engine pro-blems, only hide them. The cost of an improved system would be considerable and is not deemed warranted at this time.
- 8. We intend to conduct an electronic engine analysis on at least the Starboard main engine as soon as the vessel returns to service.
We shall obtain data to verify various operating c'urves. Various operating / load conditions will also be tested to ascertain the best engine operating points. Just what data Delaval desires has not yet been established. It should be noted that each of the above Delaval resommendations have a price tag that the State of Alaska is expected to cover. It is for this reason that we have selected only those items 'that are either necessary or would provide substantial improvement at minimal cost. We shall keep you advised of our progress and any additional problems during the overhaul. CC: Ron Linde/ Deputy Commissioner l James Eide/ Director i A.H, Mcdonald / Port Engineer Chief Engineer /M/V C0t.UMBIA I: -l
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/ December 24, 1980 I
DEI ARTMENT OF TR ANSPORTATION A.ND PL Hl.IC F ACILITIES I
/
Transamerica Delaval, Inc. Engine and Compressor Division 550 - 85th Avenue Oakland, California 94621 Attn: Mr. Clint Mathews Subj: M/V COLUMBIA, DMRV-16-4, 72033/34
Dear Mr. Mathews:
Inspite of many modifications and component change outs during the past years, new problems seem to develop faster than permanent solu-tions can be provided for the old ones. The latest new problems concern heavy piston thrust patterns on the liners, the loss of roundness of the liners which were all either new or had been factory machine honed only 7600/ hours ago, loss of liner crush and the out of roundness effecting the block and counter-bore areas in' way of the liner landings and their non-concentricity, which also has developed in 7600/ hours of operation. Old problems concerning the heavy carbon build-up on the sides of the pistons, the passage of soot into the rocker box areas, excessive wear of the valve stems and guides, pitted valves and valve seats, cracked cylinder heads, warped fire decks, etc., continue. The var-nish build-up in the liners is not new but appears considerably heavier than before. The usual liner scoring has, in severa' cases, progressed into a broaching condition, which accounted for the severe blow-by problem. One connecting rod upper bearing half was found cracked after 2400/ hours operation. All pistons have been shipped to your facility for rework of the fourth ring groove area necessitated by an apparent lack of side clearance being provided during the previous modif.ication. The piston crown diameters are being reduced. The reason therefore is obvious but it is doubtful that it will correct the basic problem. It may, however, provide a longer period of time between major liner scoring or broaching conditions. All connecting rods, not previously modified by use of new link rod boxes and cap screws of reduced size, have been shipped to your faci-lity for rework. It is understood that our spare rod cannot be so - mcdified because of a difference in the master rod bolting pattern. An explanation of this situation has been separately requested of ' your parts department. l I i )
Transamerica Delaval, fnc. Subj: M/V COLUMBIA, DMRV-16-4, 72033/34----Contd................Page ZI The new camshaft assemblies have arrived and will be installed early Jan-uary, 1981. This will also require overhaul and renewal of the cam follow-e rs . The existing turbochargers have been sent out for routine cleaning and balance work. All fuel injectors are being serviced. The suggested 1350 tips have been ordered to replace the existing 1400 units. All SME fuel pumps will be serviced. All cylinder heads are being checked, tested and rebuilt. The sixteen'new cylinder heads will.be placed on the SME for evaluation. The suggested intake manifold mounted water wash system has been ordered and installation is planned for on both main engines. All liners are being machine honed or renewed as necessary. Questions still remain regarding the cause and corrective action with re-spect to the cylinder block problems. We are in receipt of your Mr. Greg Beshouri's letters of December 16 and 18,1980, and have reservations concerning the conclusions and recommendations contained therein. This is presently under discussion with your Mr. Dave Thompson. We do request that you continue with the examination as to cause and that we be advised of the findings as soon E possible. By the end of this overhaul period, we will have modified, changed out, or reworked, at least once, every major engine component during the past six years with the ex'ception of the engine bases. Our track record does not icok very good nor does the future look very promising.
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i! Sincerely
// //-
y, , C _ [ /.' ; .4/ ,, / ! [inden Max E.'Jb Project' Engineer Alaska Marine Highway Pier 48 Seattle, Washington 98104 MEZ:abh CC: Robert Ward / Commissioner Ron Lind/ Deputy Commissioner James Eide/ Director A.H. Mcdonald / Port Engineer Dave Thompson /Transamerica Delaval Bellevue, Washington
ALASKA h f[ d t to [ Robert Ward t^u January 16, 1981 Commissioner DOT & PF W0 Juneau, Alaska 99811
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Zb'inden M/V COLUMBIA; Main Engine Status
,AP C / Report #3 Pier 48 Seattle, WA 98104 As of January 16, 1981, the following has been accomplished on subject vessel and for ease of reference is correlated to the numbered sections noted on pages 1 and 2 of the December 10, 1980, report:
- 1. The cylinder head testing and rework is well in hand and no pro-blems are expected.
- 2. The connecting rods sent to Delaval for modification have been returned. Reinstallation is pending cylinder block rework.
- 3. All pistons were shipped to Delaval by December 15, 1980, for repair work. Return date of mid February,1981 remains.
4 Removed all liners from the starboard main engine. The block cylinder bores were found egg shaped as was the case on the port main engines. Many of the liners are also egg shaped on the 0.D, and several have undersize flanges. Liners are being machined honed by the crew and those within specs will be reused. Delaval has furnished us with the modified liners wear limits. Delaval has recommended that we only restore the liner crush to original. See enclosures (1) and (2). Our concern over the pro-posed repair action was addressed to Delaval via enclosures (3) and (4), and covers the liner / block problem in detail. Delaval responded with enclosure (5) and therein again indicated that the distortion in the block bores is basically not a problem. We disagree in what appears to be a jury rig fix and especially in view of the fact that they claim the cause of the distortion has not been determined. AMT Corporation in Main, Florida made contact with us regarding machining of the engine blocks. They were apparently contacted by Delaval and advised that they were awaiting receipt of block anc liner drawings from Delaval. See enclosure (6). We briefly !is-cussed the problem, as we saw it. jfter receipt of the above drawings we arranged for them to visit the COLUMBIA on January 14, and 15, 1981. They agreed that restoration of the fit between the
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M EM O R A N DUM - -- - -- C o n t ' d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J a n ua ry 16, 1981 . Subj: M/V COLUMBIA; Main Engine Status Report #3..........Page II liner and the block was a most desirable feature. Several pro-posals and options were discussed. We are presently awaiting a telex reply due 1/19/81, as to cost and time necessary to accom-plish the repairs under several setups including 1/ shift straight time, 2/ shifts seven days a week, etc. The proceedure must also be approved by the American Bureau of Shipping.
- 5. The original turbochargers were sent out for rebuilding and have been returned to the vessel.
- 6. We are awaiting receipt of the 1300 fuel tips from Celaval so that the injectors can be reassembled. Receipt expected by Janua ry 23, 1981.
- 7. Fuel pumps are being presently overhauled for the starboard engine only for reasons previously indicated.
- 8. Modifications to the port main engine exhaust manifolds have been completed and pressure tested. Refitting of the eight (8) dis-charge elbows must await final engine reassembly.
- 9. The cylinder water wash system was ordered and receipt is pending.
- 10. The 16 new cylinder heads are on hand as previously noted.
- 11. Main bearings were checked on the port engine and found in satis-factory condition. We intend to recheck after the engine is re-assembled. If distortion remains beyond safe limits, the engine will have to be checked and possibly realigned. This cannot be properly accomplished until the engine components, that add weight to the block and crankshaft, are reinstalled.
In addition to the above, the four (4) engine camshafts have been received. The first of these should be installed by January 23, 1981. We hope to have all four changed out by the middle of February,1981. All major support bolts and capscrews on both engines have been inspected and checked for torque. All other removed engine components have been in-spected and serviced as necessary for reinstallation. i I Our best estimate at this time for completion of engine repairs en the M/V COLUMBIA takes us to the end of April,1981. Much will depend upon how we approach the manner of block and liner repairs and any associated problems. Two years ago it was suggested that consideration be given toward re-engin-ing of the M/V COLUMBI A. This was based on a history of poor performance l coupled with excessive repair costs and down time as well as the probability ! that the engine had major design problems. It did appear, for a time, that the work program developed prior to the vesse1 going off line this past season, along with that work accomplished the previcus overhaul periods, might resolve some of the major deficiencies. This appears not the case l since new problems have developed that have damaged the block and many m --
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l' t MEMOR ANDUM-------Con t ' d. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ja nu a ry 16, 1981
-Subj: M/V COLU?SIA: Idain Engine 5tatus Report 43...........Page III !
l 1 l cylinder liners. We are still living with many of, the original engine problems. Transamerica Delaval ' has ,not provided the necessary corrective: action to date. The engines might well function properly elsewhere. It is apparent that it is not suitable for our application on the M/V . COLUMBIA. Accordingly, it is recommended that action be taken to re-engine the vessel as soon as practicable. CC: Ron Lind/ Deputy Commissioner James Eide/ Director A.H. Mcdonald / Port. Engineer Chief Engineer /M/V -COLUMBIA Encl: (1) Delaval ltr of 12-16-80 (2) Delaval ltr of 12-18-80 (3) AMH Memo of 12-23-80 (4). AMH Telex of 12-30-80 (5) Delaval Telex of 12-31-80 (6) AMT l ti o f 1 81
A '. *.S K A La // //@ i l to r Robert Ward- 0^rtMarch 13, 1981 Commissioner CGT & PF ALE W Juneau, Alaska 99811 fElf PHCNE PC pow Max E. Zbinde sus;tcr M/V COLUMBIA; Main Engine Status Project Engineer Report #4 Pier 48 - Seattle, WA 98104 As of this date, the following has transpired with respect to subject vessel since submittal of the Main Engine Status Report #3 dated January 16, 1981.
- 1. Reworking of re-usable cylinder heads has been completed. Inspection of the sixteen (16) new cylinder heads revealed that the grinding com-pound had not been removed from the valves and valve seats by Delaval.
Will be done by vessels crew.
- 2. Inspection of the connecting rods reworked by Delaval revealed that the spare rod was not modified to match the remainder. Celaval advised it could not be so modified because the bolting configuration was different.
Just why is not claar. In any case, the spare rod will use different size bolts and bearings, making it non-standard but usable as a spare. It was additionally noted that the boss on the wrist pin end of the rods were not removed by Delaval although required by their modification instructions. These have subsequently been removed by the vessels crew.
- 3. The thirty-four (34) pistons sent to Delaval for warranty corrective action.concerning the fourth piston ring grotve, have been returned.
Delaval. additionally increased the piston crown to liner clearance per their recommendation. They did not remove the sharp edge from the bottom of the piston skirt per our request. This has been subsequently acccm-
.plished by the vessels crew. It has also been learned that this portion of the original piston modification is no longer being accomplished. We assume for the same reason that we requested it be eliminated.
Inspection of the returned pistons revealed that the roll pins, which lock the securing nuts in position, were left out of two (2) pistons. These will be installed by vessels crew prior to installation. l 4 All re-usable cylinder liners have been honed by the crew. Sufficient numbers of new liners were ordered and have been received to permit engine re-assembly. Each new liner will have to be thoroughly inspected and fitted during installation due to variations in the new liners and the possibility that machining errors exist. One of the new liners has the old style internal finish which will be corrected by the crew.
- 5. Because of extensive cracking of both the Port and Starboard main engine
- cylinder blocks, the original plan to effect inplace repairs was dis-l pensed with. Four (4) new cylinder assemblies were finally ordered for i
installation.
.. Robert Ward March 13,1981 Commissioner '
Page II SUBJ: M/V COLUMBIA; Main Engine Status Report #4 MEMORATIDUM..... Cont'd - Further engine examination revealed that the main block on each engine also have cracks. These are not deemed critical at this time. The main blocks on both engines were checked for alignment and warpage by use of laser beam alignment equipment. Distortion was evident in both units. The port unit had to be released from the foundation and the flexible crankshaft drive coupling opened to eliminate same. The port engine will therefore have to be com-pletely realigned, re-chocked and re-doweled to the foundation after reassembly. The torque on the main block to base through bolts were found at considerable variance from manufacturers specifications. It appears quite probable that these bolts were improperly torqued at original engine assembly. It is also suspected that considerable fr_etting has occurred between the mating surfaces of the main block and the respective bases, much the same as found between the main block and the cylinder blocks. It is hoped that we can live with these f.retted areas for a time. All the main block to base through bolts on both engines have been loosened, cleaned and retorqued met to manufacturers specifications. Three of the four new engine camshaft, were change out prior i' the
@ termination that the cylinder blocks could not be effectivel re-paired. The fourth camshaft assembly was found to be not new 1at in fact a rebuilt unit containing several damaged bearing jourical
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areas. This unit .wa. returned to Delaval for exchange. The cam-shafts which had been installed were again removed to permit change out of the cylinder blocks. The first pair of new engine cylinder blocks were receised, placed aboard and have been installed on the Port engine. The e have been aligned and are presently being torqued down. , Delaval requested that we ship two o'f the original cylinocr blocks to ! them for their inspection, prepaid. See enclosure (1), b.o of the blocks have been shipped freight collect. See enclosure (2). The two remaining blocks are on board and will be removed upon receipt or the second pair of replacement blocks and will be retained in Seattle. These two cylinder blocks, one from each engine,'are the most signi-ficant with respect to failures.
- 6. The turbocharger nozzle rings were cleaned and checked for blade angle.
! A volute section on one turbocharger was found cracked and was re-placed using vessel spare. The four turbocharger units have been ! reassembled and are ready for reinstallation. l __y
I l Robert Ward Maren 13, 1981 l Conmissioner Page III
-SUBJ: M/V COLUMSIA; Main Engine Status Report #4 '
MEMORANDUM..... Cont'd
- 7. The new 1300 fuel tips have been received from the vendor and are being installed in the fuel injectors. These will be ready for installation along with the fuel pumps when needed.
- 8. Refitting of the eight (8) discharge elbows on the port engine exhaust manifolds is pending engine reassembly. All four exhaust manifolds have been rigged off the engines to pennit cylinder block change out.
- 9. The cylinder waterwash system has been received. We are awaiting in-stallation plans and details.
- 10. With respect to the newly received cylinder blocks, it was .found that the threaded head stud holes were not counterbored deeper as Delaval had indicated they currently do. This to eliminate cracking of the cylinder block in way of the stud holes. The vessels crew is there-fore remachining each of the 256 head studs to accomplish the same intent. This would not have been necessary had the blocks been machined as originally indicated.
We expect to be fully engaged in reassembly of the Port main engine by March 16,1981. Receipt of the remaining two cylinder blocks for the Starboard engine, is still scheduled for mid April s 1981. Barring any un-foreseen problems, the May 29, 1981, departure date still appe.a.rs realistic. The new problems found on M/V COLUMBIA's mai'n engines, during the last months, has only reinforced our position concerning the un-suitability of the engines in our application. We have also received severai in-formal inquiries from other Delaval engine operators and are aware that others are having similar problems. One call received early this week, from a Texas based firm, revealed cylinder block cracking problems on Delaval in-line (not vee type) engines. In conjunction with non-destructive testing and alignment checks, per-formed by Todd Pacific Shipyards on M/V COLUMBIA engines, an engine evaluation / study report is being prepared. It should be in hand by the first of next week. This report should provide input from an outside source as to suitablility of subject engines. CC: Ron Lind/ Deputy Commissioner James Eide/ Director A.H. Mcdonald / Port Engineer Chief Engineer /M/V COLUMBIA Encl: (1) Transamerica Delaval l tr of February 13, 1981 (2) Alaska Marine Highway 1tr of February 23, 1981
o SKA 1/L // L to r File ^"- April 9, 1981 fitE NO: A
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FROM-
- f. fax b den SUBXCT: M/V COLUMBIA: Engines Assistant Port Engineer S/N 72033/34 Seattle The attached is a listing of some of the difficulties experienced with Transamerica Delaval Inc., thus far during the current engine overhaul program. It is by no means all inclusive but does c:ver the items of maj.ar importance. Several of these could have resulted in severe engine casualties had they not been noted by the owner. It indicates that some major problems exist with respect to Delaval's inhouse Engineering, Production, Quality Control and Parts Departments.
the situation is not new and it aapears to be getting worse over the years. It causes delays, requires excessive manhours, results in excessive costs, requires that the owner act as the manufactures quality control agent and field engineering activity. Add to the above the basic problem wherein year after year the Transamerica Delaval engines on M/V COLUMBIA have demonstrated them-selves to be incapable of providing, and/or unsuitable in, the service for which they were furnished. The results are totally unacceptable. This data is furnished for information of those involved. It may be useful should the matter be discussed with Transamerica Delaval or pressure applied by some other means. Difficulties experienced with Transamerica Delaval thus far durir4 the 1980 - 81 M/V COLUM8IA Main Engine Overhaul.
- 1. Tw) engine sets of pistons were sent to Transamerica Delaval for rework on 3.0. 590993.
This to primarily correct for a machining error caused by them during a prior manufactures piston modification. A new manufactures modification was to be accomplished wherein the
?iston crown diameter was reduced in an effect to reduce the destructive action The Stat' of the carbon buildup in this area on the cylinder liners.
piston s < letof be Alaska separately requested that the sharp edge on the removed. and did trore harm than good.This We was a part of the subsequently earlythat learned piston thismodification sharp edge is no longer a part of the manufactures piston modification. , l l
e' File . April 9,1981 -
,. Page 2
- The pistons were returnd but without the' sharp lower skirt edge re-moved. This was accomplished by the owner by hand and involved 34' pistons._ Inspection of these pistons, supposedly ready for use, revealed that several haf not been fitted with groove pins, part
#GC-006-039. The consequences could ha've been disastrous had this not been detected by the owner.
- 2. Owner ordered 20 each 1 " connecting rod capscrews and washers to ' replace those installed new 'last year. The units installed last year,on five rods reworked to replace the five cracked ones, were apparently of. incorrect material and/or hardness. Delaval furnished 17/8" connecting rod capscrews which would not fit and which were returned to them for exchange on RMR-9138. The proper capscrews have not been received to date.
- 3. The owner ordered two each cylinder blocks on D.0.#586416 and two i additional ones on 0.0.#591633. These to replace the installed units !
.which had fretted surfaces, were distorted and cracked. Inspection H
. of the damaged cylinder blocks by the owner and Delaval Engineering i personnel resulted in a plan to counterbore the head stud holes on the new blocks approximately one inch deeper for a specific reason. . This action would also permit the use of the existing 256 head studs. The first two blocks arrived at pier 48 without advance notice as
, had been requested. These units weigh approximately 13,000 lbs. each -
l and special cran.e and handling services must be arranged for. Delaval was again requested to advise us of the second shipment to prevent delays and added costs in handling the cylinder blocks. The second set again arrived without advance notice. .
, Additionally, the head stud holes had not been counterbored as pre-viously planned.. This required that the 256 cylinder head studs each be machined and modified at our expense. Drawings furnished by
, Delaval Engineering Department to assist us in the stud modification were not applicable to the studs in question. The owner made it's
- own modifications and machined the studs to obtain the desired resul ts.
- 4. The new cylinder blocks differed slightly from the originals. The i
changes appear to be an attempt to correct for problem areas apparently suffered by other engines, problems possibly similar to ours. Upon engine reassembly, it was found that approximately 50% of the fuel pump bases would not fit the block because of these modifications. l This . required that modifications be: accomplished by the owner to permit the proper installation of the fuel pump bases. i l i l
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File April 9, 1981 Page 3
- 5. New cylinder. liners were ordered on D.0. #591346 to replace those worn beyond further use. Of those received, one had a Parkerized finish which to our knowledge had not been used for years. Another had the heavy cross-hatch finish, which we had been advised prior to this overhaul, was no lo'nger used. Both of the above conditions were corrected by the owner. A third new liner was received with its flange thickness larger than manufacturer maximum manufactures tolerence. It will be installed as furnished.
- 6. Four new camshafts were ordered on D.0. #589782 to replace the installed units which were failing. Three of the four camshafts received appeared new. The fourth one was a used one whose bearing journals were far worse than those being replaced. This required that it be returned to Oakland for exchange.
- 7. Sixteen new cylinder heads were ordered on D.0. #590247 to re-place the worst of our existing 32 heads, some of which are beyond repair. All the new heads, of supposedly improved type, were re-ceived with valve grinding compound on both the valve and head seating surfaces. This required that the owner remo.ve the valves, 64 in total, from the assembled heads to permit removal of the compound.
- 8. D.0. #590246 required reworking of 13 each existing connecting rods. This rework was based on the manufacturers recommendation.
The modifications were the same as performed on five (5) rods which cracked last year. It basically reduced the size of the connecting rod capscrews from 17/8" to lh", which required that the link rod half of the rod assembly be replaced. The entire assembly was then fitted with a .030" oversize bearing. The spare rod was returned without rework because it had a re-portedly different bolting set-up than the rest. This apparently prevented accomplishment of the modification. A formal explanation of the problem was requested but no reply has been received. We erred and sent by mistake one of the previously modified rods. That fact should have been evident during their shop inspection but was never called to our attention. Had they done so, we could have sent down the one rod that shou'd and could have been modified. They additionally billed us Ter reworking of the rod sent down by mistake. All of the connecting rods were returned to the vessel. However, on 6 April 1981, the new washers and 1h" cap screws were found gaulled and unfit for use in the engine. 4
(ie April 9, 1981 Page 4 The washer and thru-bolt nuts on the rads were likewise gaulled. This damage was caused by the Oakland facility whom sent out the connecting rods, supposedly ready for use, Had not the owner dis-covered the situation, the results could have been disastrous. We are presently awaiting receipt of two engine sets of -the washers of proper hardness. Since new replacements for the defective thru-bolt nuts and capscrews are'several weeks 'away, we now have to send our thru bolt nuts and the 1 " capscrews to the Oakland facility where they will be dressed up enough'to permit use. Hopefully, this operation can be expected to prevent further delays in our engine overhaul. cc: R. Ward, Commissioner, D0TPF R. Linde, Deput/ ommissioner, C 00TPF J. Eide, Director A.H. Mcdonald, Port Engineer , M. Griggs, Administrative Officer C/E M/V COLUMBIA
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- o. ALASKA /
ro [- DATE. Appj j gg, ]gg] FILE NO reterscNE NO 7 now SUB ECT: M/V COLUMBIA; Engines
.ax Zbinden Assistant Port Engineer S/fl 72033/34 Seattle, Washington Scme of the difficulties experienced with Transamerica Delaval Inc.,
in regard to part support, shop work and engineering, were noted in my letter to file dated April 9,1981. The situation and conditions continue as noted below: 4-13 A question developed regarding~ camshaft locations. The locations and respective part numbers were recorded at the time the four original engine camshafts were removed from the port and stbd engines. Installation of the two camshafts in the port engine presented no problem. The part numbers agreed with those removed and agreed with the data contained in the sers!ce manual. However, the manual did not agree with the original set up in the stbd engine wherein the camshafts are shown installed in a reversed position from what we recorded during removal. Delaval was contacted to verify proper installation. We were advised that the manual was incorrect and that the stbd camshafts should be installed as they were originally. This is not the first time the manual was found in error. Had we not recorded the original camshaft part number positions, and proceeded to install them per the manual, considerable delay in completion of the stbd engine reassembly could have resulted. 4-15 Found that approximately 2/3rds of the fuel cam tappet assemblies could not be installed on the stbd engine. As they were , being inserted into the campocket area, they jamed against the cam-shaft and could not be placed into position. Investigation revealed that the machined portion at top of the new cylinder blocks, thru i which the neck of the tappet assembly protrudes, were of varying { thickness and were not relieved with a counterbore as were the l original blocks. This orevented installation of the fuel tappet assemblies with the camshaft in place. To continue with engine i reassembly in a timely manner, each of the effected tappet assemblies was milled by ship's engineers to provide for installation clearance. It should be noted that this. problem did not exist on the port engine.
- File - April 29,1981 Page 2 4-15 Had difficulty in establishing proper crush on liners in stbd engine inbd cylinder block. Renoved liners and found liner-counterbore depths in the new cylinder block off by at least .003" in the 12 to 6 o' clock position. Indicates poor set up by Delaval prior to machining wherein the centerline of the counterbore is not parallel to the block top face. Obviously, we did not have time to obtain a new block nor did we feel that boring and installation of a liner flange shims in a newly furnished block was an acceptable repair action. We therefore selected liners with the greatest flange thickness for installation in the inbd cylinder block. This would give us at least the minimal liner crush on one side although the opposite side would be excessive. This condition will no doubt have an effect on the service life of the newly installed stbd engine inbd block, liner and cylinder head assemblies. Additionally, had to relieve the sharp corner on each new liner flange because of interference in the counterbore. This condition was known, at least two years ago, as a problem area which caused liner failure. Apparently, the owner still must relieve each new liner.
4-20 Called DeLaval to remind them that 32 retainer rings, apparently removed from our reworked pistons, had still not been returned. It was requested that they either locate and return the missing rings or furnish us new ones. New ones were received on 4-23-81, however, late delivery caused us two and one-half days delay. This had to be made up by additional overtime work on the - part of the crew. 4-23 Experiencing problems'with installation arrd timing of the stbd main engine air start distributors. A minor problem resulted on the port engine which required grinding away of a portion of the original engine base to permit clearance for proper timing of the air start distributors. They apparently were never properly timed at the facto ry. The situation on the stbd engine was more serious and corrective action required complete redrilling and doweling of the adapter plates to permit proper distributor timing. If the problem was not caused by original poor. factory installation, the possibility exists that the drillings on the aft end of the newly furnished camshafts were off in relation to those on the original camshafts. 4-24 Inspection of air shipment of connecting rod three bolt nuts, which had just been reworked by Delaval because of damage caused by them during connecting rod modifications, revealed the majo ity to be nicked on the newly machined surfaces. They apparently were machined properly but then mishandled in such a manner that they became damaged. The nuts were then reconditioned by the crew. 4-28 While preparing. the 16 new cylinder heads for installation on the stbd main engine, new difficulties were encountered. This in addition to the grinding compound found left by Delaval on the valve 1
File April 29,1981 Page 3 seats and reported earlier. Considerable weld splatter as well as nicks, dents and heavy scratches were found in way of washer and gasket seating areas. Accummulations of scale, sand, metal shavings were found in the water passages, stud holes, injector and air start passages, etc. Corrective action furnished by the crew. Welded side plates appear to be of varying thickness between heads. Repair welding was readily evident on all the heads to varying degrees. The heaviest concentration of repair welding appeared in the area of cooling water outlet port. Further examination revealed that these outlet ports were out of position in relation to the associated water jumper line stud holes, on nine of the sixteen newly furnished heads. The th.ickness of the head material from the inside upper portion of the water port to the top of the head was measured and found to vary between .700" and 1.225". This indicates that Delaval had a problem with shifting of the casting cores. This lowered the location of the water outlet port on the cylinder head. When connected to the outlet water jumper line, a mismatch occurs wherein the excess metal thickness at the top (that portion over .700" thick) causes a water outlet flow restriction. Likewise, the bottcm of the port then falls below the mating jumper line flange a like amount causing a similar restriction. It appeared that Delaval attempted a partial fix by adding weldment to the bottom edge of the water port to provide the sealing surface for the gasket. On several heads, this only compounded the problem and caused as much as 50". loss in the outlet por,t opening before adding the outlet jumper line. On some heads, the bottom of the water outlet port is so low that once the exhaust elbow is in place, no surface is left fo .ne water outlet jumper line gasket to seal against. From our standpoint, nine of the 16 newly procured cylinder heads (total cost of $237,785.47) are defective because of the water outlet port location problem. The heads are obviously not in accordance with their drawings. Operation with the cylinder heads in question will quite likely result in premature damage and/or engine failure. Delaval was verbally infonned on 4-30-81 that the 9 cylinder heads were considered defective and that corrective action, under their replacement part warranty provisions, was immediately required. The effect of this latest problem on our trial and sailing dates is dependent upon their pending action and our acceptance. Each and every problem area noted in this and the letter to file,.of
- April 9,1981, have brougit to the attention of Mr. Dave Thompson, i the local Delaval resencative. Unfortunately he can do little other than relay them to Delaval, Oakland.
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i File April 29,1981 Page 4 Based on the degree of engine overhaul and the many trouble areas encountered during the engine rebuild and presumably reported to them by their local representative, it is surprising that no one from Delaval has visited the vessel these last months to really survey the situation. The only exception was the shop representative we requested to assist in positioning the new cylinder blocks. One could surmise they are only interested in selling parts and service regardless of the situation. The condition of many of the parts and ship rework items also suggest they are not interested in making the engines operate properly. cc: R. Ward, Commissioner, D0TPF R. Linde, Deputy Commissioner, DOTPF J. Eide, Director, AMH A. H. Mcdonald, Port Engineer, AMH M. Griggs, Administrative Officer, AMH , C/E M/V COLUMBIA A
1
.d SKA 1 $i l rO, r- DATE: June 1, 1981 '
I FILE NO-J TELEPHONE NO F90% Max Zbinder 'j,'
SUBJECT:
M/V Columbia; Main Engines Assistant fors gineer S/N 72033/34 Seattle, WA s v 4 This is the final report concerning the 1980-81 rebuilding of subject main 3 engines. In my letter to file of 29 April,1981, the matter of the defective newly received cylinder heads had not been resolved. Delaval subsequently agreed to provide corrective action and engaged Todd Shipyard, of Seattle, to weld up and grind the weter outlet ports. The intent was to reposition the ports to provide an acceptable cooling water flow. Only five of the nine cylin-der heads in question were so modified. By " acceptable", it is meant that the ports line up with the mating cooling water jumper line sufficiently. well to provide what Delaval calls adequate engine cooling. It should be noted that this is less than what we have had in the past and less than would be available had the heads been manufactured as per their engineering d rawings . It should be noted that at least a portion of the recent engine difficulties are related to thermal problems of which engine cooling and heat transfer are important factors. . Because of the time element, we had no recourse but to install the new heads and hope for the best. All programmed work regarding the main engines was accomplished with exception of the water wash system installation. This was planned for acccmplishment on both main engines based on Delavals re-commenda tions. The necessary components were ordered from them on 11-4-80 but have not been received to date. We intend to install same as soon as received. Sea trials were satisfactorily conducted on'19 M' ay, '1981, without any major problems. One of the two newly installed port main engine ethaust manifold water cooled head plates developed a leak at the start of the trial. Ex-amination after the trial revealed cracks around 2 of 3 tie rods which penetrate the outer port plate as well as a large crack in the weldment between the two upper exhaust outlet ports. These were ground out, ' revealing poor initial weldments, and were rewelded. An electronic during the seaengine trials.analysis was conducted on the starboard main engine The results were interesting but revealed no major engine problem with respect to timing, fuel inspection, pressures, etc. The reasons for our continual engine problems therefore again appears related to inherent design problems. i
e i' " File" Page 2 A quick run-down of costs related directly to the main engine rebuilding, dis-counting routine items, is as follows:
- 1. Delaval' furnished parts and services . including freight. $942,282.96
- 2. Othe , for support services., 149,620.46 TOTAL $1,091,903.41 1
The above is incomplete since:all final costs are not in. It does not in- , clude approximately $340,000.00 worth of engines crew costs. i
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MEZ:cip _ cc: R. Ward, Commissioner, 00T/PF R. Linde, Deputy, Commissioner, D0T/PF J. Eide, Director, AMH~ -) A. H. Mcdonald, P/E, AMH l M. Griggs,' Administrative Officer, AMH R. Snyder, APE, Juneau C/E M/V COLUMBIA s h e i e I k e}}