ML20101U262

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Statement of Matl Facts as to Which There Is No Genuine Issue Re Issue 16 Concerning Reliability of Tdi Diesel Generators for Emergency Onsite Power
ML20101U262
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/05/1985
From: Reggie Sullivan
CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20101U246 List:
References
OL, NUDOCS 8502070213
Download: ML20101U262 (13)
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February 5, 1985 COCYETED U3NRC UNI'IED STATES OF AMERICA 85 FEB-6 P4 51 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CFrt:EcrSECFfT/;vy C0;inTig; , g p; ;;*

J Mi:q In'the Matter of )

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THE CLEVELAND ELECTRIC- ) Docket Nos. 50-440 .

ILLUMINATING COMPANY, ET AL. ) 50-441

. . )

-(Perry Nuclear Power. Plant, )

Unit.s l'and 2). )

. APPLICANTS' STATEMENT OF MATERIAL

, FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON ISSUE-16

-Pursuant to 10 C.F.R. 5 2.749(a'), Applicants, in support of their Motion'for Summary Disposition of Issue 16, state that

'there is notgenuine issue to be heard with respect to the following material facts:

1. ' Issue 16' states that-Applicants have not demonstrated that the four Trans' america Delaval, Inc. ("TDI") diesel generators:in place at_the Perry Nuclear Power Plant ("PNPP")~can reliably generate-emergency on-site power. ASLB Memorandum and-Order, December 23,- 1983,.
2. The TDI Diesel Generator Owners Group Program provides lassurancethattheTDI.dieselgeneratorsinplaceatPNPPwill reliably perform their-safety-related functions by establishing

.both-the reliability-and; acceptability of their critical engine m:;

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components. Affidavit of John C. Kammeyer ("Kammeyer Affidavit"), 1 31. The Program Plan established by the Owners Group provides an in-depth assessment of the PNPP diesel generators' ability to perform their safety-related function through a series of component design reviews and quality

'revalidations,' engine tests, component inspections,.and the establishment 6f maintenance requirements. Kammeyer Affidavit,

_11 6,: 9.

3. The NRC staff evaluated the Program Plan and concluded

.tiat it incorporates che essential elements needed to resolve the

-outstanding concerns relating to the reliability of the TDI

' diesel generators for nuclear service, and to ensure that they

- comply-with GDC 1 and GDC 17. Id., 1 7.

-4. Cleveland, Electric Illuminating Company ("CEI") is a

-member of the Owners Group and actively participated in the.

Owners Group Program Plan. Id., 1 4; Affidavit of Edward C.

.Christiansen ("Christiansen Affidavit"), 11 4, 5, 7-19.

15 . High-quality technical' resources were used to implement-

'the Owners 1 Group Program. Kammeyer' Affidavit,--1 6. . Spanning.

over'a year's time, more than a hundred engineers and technicians

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were involved-in the Phase-I effort alone-(see31 7 below). Id.,

1.13.. This. ensured that the-. evaluation of1the TDI diesels would-4 be. thorough;and meaningful. Id.,-1 6.

6. The._ Owners Group compiled a comprehensive database on Idiesel generator operating experience to provide a foundation for the1 selection-of-. components for review. _I_d . . ' 11 8, - ~ 15 . The p

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sdatab'ase~ included information from both nuclear and non-nuclear

_ ,. industry experience as well as utility site-specific experience

,with diesel generators. 'Id.

7.- The'" Phase I" effort of the Owners Group Program has identified each~significant known problem with potentially 1 generic; applicability to TDI diesel generators. Id., 1 8.

FSixteen' components were identified for which specific design and/or manufacturing _ concerns were raised. Id., 1 9. The

, crankshaft 1was among the component. identified and evaluated.

Id.,,11 8, 10.

8.- A detailed design review of each of these sixteen

, components was conducted by the Owners Group consultants. Id.,

1 9. Their analyses, results, and conclusions are outlined in a series of-thirty-six separate reports which have been submitted

- --to-the NRClfor review.

Id., 1 13; and see Christiansen

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m  ; Affidavit,il 4. The' Phase I reports contain recommendations for maintenance, inspection,-testing and recommendations.concerning.

Loperating procedure's and procurement. specification requirements, f Christiansen' Affidavit,'1'4.'

g j, 19. CEI employed an independent' engineering consulting p firm,fSouthUest Research Institute-("SwRI"-),.to verify tlie

fapplicability of-each. Owners' Group report:to the-specific

& Ecomponent in place ats PNPP. Id. 1;6. SwRI concluded that each

~ <s . tof-the; sixteen Phas'e licomponents'in place at PNPP,is acceptable.

r forDnuclear ! service =if: the ' applicable . Owners Group maintenance'-

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- andJinspection recommendations,uasLwell as'those of SwRI are y

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followed.- Affidavit of Charles D. Wood III (" Wood Affidavit"),

11 181-182.

10. ?While TDI drawings and certain TDI information were

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usedias input to the Owners Group review of the diesel generator

-components-(in both Phase I and Phase II, as discussed below),

all technical ~ evaluations were performed independent of TDI.

. Kammeyer Affidavit, 1 11. Independent design verification of

, each component requiring a design review was achieved by the establishment of a methodology for verification of the critical

- attributes of the component and their evaluation by the Owners

, . Group,; not'by a' review of'TDI's analysis. Id. The Owners Group

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-Program achieved independence from TDI's Quality Assurance

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LProgram by the inspection and testing of the TDI diesel generator

equipment installed at each site. Id., _1 12. These inspections-

'o Ewere performed by Owners Group and/or site personnel. Id .- Thus,

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. critical' aspects of. components actually installed in-~the diesels f were verified 1 independent,of TDI. Iji.

'll . - .-PNPPJhas incorporated all of the applicable Phase I Owners: Group' recommendations into its TDI engine program.

Christiansen. Affidavit, 1 5. Where1 required,-Phase'I: components-t (were inspected by a task force of PNPP p'ersonnel.and/or Owners
Group
representatives during the engine revalidation' effort.

.~Id.,711 10-15. ; Ongoing 1 maintenance recommendations from the 7 ,

Owners' Group, as.well as SwRI's recommendations,;are.being

) incorporated intoltheL engine'. maintenance program at .the -plant.

J_d.,:111~16-17. Owners Group requirements will be. reflected in :

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3-specifications provided in all future purchase requisitions.

Id., 1 22.

12. Based on the Ownerfs Group and SwRI's evaluations, as
well as the implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel i

generators' turbochargers are acceptable for their intended nuclear service. Wood Affidavit, 11 143-152.

13. Based on the Owners Group and SwRI's evaluations, as zwell as-the implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel generators' base and bearing caps are acceptable for their intended nuclear service. Id. 11 34-35. ,
14. Based on the Owners Group and SwRI's evaluations, as well as the. implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel generators' crankshafts are acceptable for their intended nuclear service. Id. 11.161-172.
15. ' Based on'.the Owners Group and SwRI's evaluations, as well as the. implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel generators' cylinder blocks and cylinder' liners are_ acceptable

~. for-their intended nuclear service. Id., 11 131-142.

16. Based on_the Owners Group-and SwRI's evaluations, as

.well.as the implementation of applicable inspection, testing, and

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f' .. maintenance recommendations at PNPP, the PNPP TDI diesel D generatorn'~ cylinder head studs are acceptable for their intended nuclear service. Id., 11 108-118.

'17. Based.on the Owners Group and SwRI's evaluations, as well as the implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP'TDI diesel generators' connecting rods are acceptable for their intended

-nuclear service. Id., 11 173-180.

18. Based on the Owners Group and SwRI's evaluations, as well as 'the implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel

. generators' connecting rod bearing shells are acceptable for their intended nuclear service. Id., 11 46-59.

19. Based on the Owners Group and SwRI's evaluations, as well as the implementation of applicable inspection, testing, and maintenance-recommendations at PNPP,-the PNPP TDI diesel generators' pistons are. acceptable for their intended nuclear service. Id.v'11'119-130.
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20. ' Based on the' Owners Group and SwRI's evaluationsi as well as the implementation of applicable inspection, testing, and-imaintenanceLrecommendations.u*. PNPP, the PNPP TDI diesel

. generators' airstart. valve capscrews are acceptable for their-intended nuclear service. Id., 11 80-90.

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  • ! ; , T 2'l . - Based on the Owners Group and SwRI's evaluations, as

.well'as'the implementation"of applicable inspection, testing, and ma'intenance? recommendations at PNPP, the PNPP TDI diesel (generators'-cylinder heads are acceptable for their intended l nuclear service. .Id.,.51 67-79.

. 22. Based.on the Owners Group and SwRI's evaluations, as

'well as the implementation of applicable inspection, testing, and maintenance recommendations at PNPP, the PNPP TDI diesel igenerators' fuel oil injector tubing are acceptable for their intende'd nuclear service. Id., 11-24-32.

12 3 . Based on the Owners Group and SwRI's evaluations, as Chellias the implementation of applicable inspection, testing, and

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- maintenance recommendations at PNPP, the PNPP TDI diesel generators' mainJand: connecting pushrods are acceptable for their intended nuclearJservice. Id., 11 91-107.

24. . Based on theLOwners Group and SwRI's evaluations,- as x -

~J u .well as the-implementation:of applicable' inspection, testing, and zmaintenance recommendations ~at-PNPP, the PNPP TDI diesel R i generat' ors' rocker arm capscrews are acceptable for their Lintended nuclear: service. Id., 11 12-23.

125., Based'on the. Owners Group {and'SwRI's evaluations, as

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wellfas.the. implementation of applicable inspection, testing, Land.

s imaintenancelrecommendations.at PNPP, the PNPP'.TDI diesel 4- -generat' ors'-jacket waterfpumps'are acceptable for their" intended nuclear' service. Id. , ;11 153-160.

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- 26. Based on the Owners Group and SwRI's evaluations, as well as the implementation of applicable inspection, testing, and

- maintenance recommendations at PNPP, the PNPP TDI diesel generators' wiring and terminations are acceptable for their intended nuclear service. Id., 11 60-66.

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27. " Phase II" of the'O.wners Group Program examined the important components of each owner's engine which were not reviewed in the Phase I effort. Kammeyer Affidavit, 11 14-27.

PNPP diesel generator components were examined from the standpoint of both design and quality attributes. Id., 1 14; Christia'nsen Affidavit, 11 7-11.

2 8. - The Phase II components were chosen on the basis of past nuclear and non-nuclear engine experience, as well as site-specific experience, as entered into-the comprehensive database discussed supra. Kammeyer Affidavit, 11 14-17. The Jeffect tte component's failure would have on the performance of-the diesel generator was also evaluated and each component was

-classified according to its criticality. Id., 1 16.

29 .- ' Appropriate' design review and quality revalidation

requirements were. established for each component,'as reflected in

'the'more. detailed task descriptions which were prepared for each-component. Id., 11 18-19, 22. Components whose failure would result in'immediate diesel generator shutdown or prevent start-up under emergency conditions normally required a full' design review, and quality revalidation. .Id., 11 16-17. The task description f

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] - for-each PNPP component was then implemented by a PNPP task force at.the. site, with detailed design reviews being conducted by the

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. Owners. Group. Id., 1 22; Christiansen Affidavit, 11 8-11.

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n 3 0'. The Phase II effort has been completed at PNPP. The

PNPP DR'/QR Report was transmitted to the NRC on January 17, 1985.

h- 'Christiansen Affidavit 1 8.

As noted in the DR/QR Report, Ep .' selected engine components (as recommended by the Owners Group) will be inspected following approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of operation oni each of .the . Unit 1 engines. Affidavit of Gary R. Leidich

.("Leidich' Affidavit"), 1 21.

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31. All unfavorable inspection results have been documented n;

according to' established PNPP procedure, evaluated and resolved.

-E .Christiansen-Affidavit,,1 13. A problem with the engines' rocker Larms and one.with the crankshaft oil holes were the only two

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Lnotable concerns; encountered. Id. 11 14, 15 . - Both problems were Lcorrected according'to procedures recommended'by the Owners. Group.

1. innd TDI . ' Id. -

' . 132.  ;

Where,.the' Owners Group recommended " ongoing"

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? maintenance'for:a Phase:II component"to assure its: reliable yerf rmance, .this-! maintenance'. requirement is being incorporated'

  • - linto tho' ongoing'PNPP-preventative' maintenance program. M.,

'SwRI: recommendations relating to the Phase I-

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11 16-17. .. .

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-components,will also be incorporated.into PNPP's engine s: , - . . .

.-maintenance program. M. ' Specifications,for Phase II. components

,' f provided'in all future purchase requisitions willfalso reflect y' .

cany pertinent. Owners Group) requirements.- Id ._ , .1. 2 2.

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I , 33. The two PNPP Unit 1 TDI diesel generators will be b .{l

,Osubjected'to-a; comprehensive cesting program coupled with specific component inspections prior to plant licensing and 1 operation.~ - Leidich Affidavit, 1 7. This program will provide

additional-assurance of the reliability of the TDI diesel generators' ability to perform their intended safety-related
a function.' -M.
34. .The preoperational engine' test program for the Unit 1 7 diesel' engines is based on IEEE-387-1977 and NRC Reg. Guide

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?l.108, Rev. 1, August 1977 (as described in Table 1.8 of the PNPP

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FSAR). M ., 1 8. -

The program includes testing and inspection

, . . recommendations-developed by the Owners Group. M.

35. .The " lead" engines'for the model DSRV-16-4 engines

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'gd . installed at PNPP have already undergone-successful

  • pre-operational testing. M., 1 9. The TDI DSRV-16-4 engines at'.

-Comanche? Peak were-successfully' tested in a program based on IEEE Std. 387', Reg. Guide 1.108,'and the additional Owners Group' tests-

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(including:a torsiographitest of the crankshaft and engine

(, p xvibrationj tests ) .-

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M . In excess of 100' hours of operation were

?l'oggedton theserengines'.--The TDIfDSRV-16-_4._ engines at.the:

Cata'wba. plant:haveiover 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />?of-successfhl operation. M. ,

, x- 31 $10. The successful operat' ion of these engines'provides

, indditiona12 assurance.ofSthe c'apabilities of the DSRV 4 engines -

[ instal' led ' at 'PNPP. JId.,

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The testLprogram developed'for PNPP'

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incorporated'information obtainedLfrom the testing _at these
other-plants!as.welllas-input from routine'. reporting and surveillance-

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programs such'as 10 C.F.R. Parts 211and.50.55(e). M ., l'11.

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t i' 36. The PNPP diesel generator auxiliary systems will be

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tested to-demonstrate the proper functioning of the electrical and pneumatic 2 controls for the diesel generator auxiliary systems, which include the starting air, jacket water, lube oil, and fuel oil systems. Id., 1 14.

37. . Diesel generator control circuit functional and start
tests will be conducted at PNPP to demonstrate electrical and pneumatic: control circuit operability in the " Manual" mode of operation for both Unit 1 diesel generators. Id., 1 15. Each diesel-generator will be tested to demonstrate that it is capable of starting, achieving rated voltage and frequency within acceptable limits and time, and accepting load in the various

'mo' des of. operation. Id., 1 15.

38. Diesel. generator load tests will be' conducted to demonstrate the capability of both Unit 1 diesel-generators to start, l'oad.to'100 percent of full-rated-load,Jand achieve steady-state-temperature equilibrium. Id., 1 16. Each diesel

--l generator.will demonstrate its operational capacity.at.100 percent; load for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> within design and operational

. parameters. ;Id. Each diesel generator's capability toLreject:

100 percent rated load without. tripping due to overspeed will be-tested. Id., 1 16. .

39. Diesel generator load acceptance tests will be-

' performed to demonstrate the capability of both Unit 1 diesel generators to start upon. receipt of a. start signal and.to independently accept. design'. loads without exceeding manufacturer specifications and design criteria. Id., 1 17.

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140. Diesel generator reliability tests will be conducted to demonstrateSthe~ starting performance of both Unit 1 diesel generators by the performance of a minimum of 69 total valid L

tests with no failures, in accordance with the criteria specified

,~ in1 Reg. Guide 1.108, Rev. 1 Section C.2.a(9) and C.2.e. Id.,

off18.

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PNPP will perform 20 additional tests, 10 on.each of the

' Unit 11' diesel generators. Id., 11 18-19. Each of the

= start-and-load tests will'be documented on'a chronological. test

log in accordance with Section 3.0 of Reg. Guide 1.108. Id.,

.f.19.

41. . Testing recommended by the Owners Group to confirm the adequacy of selected components will also be performed at PNPP.

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fId., 1 20. A torsiographitest to confirm.the adequacy of the

crankshaft-to withstand operating torsional stresses will be 4

Lperformed. .Id. An engine-baseline vibration survey will be

-taken~to determine the initial vibration characteristics of both A J ~

-Unit 1 engines. _ Ig.

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42 . - LTDI-recommended hot;andicold crankshaft defl'ection

. measurements will also be performed prior:to.preoperational

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. testing to verify the: adequacy ~of the. crankshaft. Id. , z 1'20. At r; . PNPP,:an: additional measure o'f the performance of each cylinder on.each-of the.. engines will1be obtained.by logging-cylinder

? exhaust' temperature sensor readings under load. Id., 1 13.

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s - ' -43. Surveillance and reporting' programs in pl' ace at PNPP,-

' including.those established; pursuant:to 10'C;F.~R. Parts 21 and

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? 50.55(e),2 will- continue tto : identify and monitor? any _ problems with.

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. :the;TDILdiesel: generators. 'Christiansen Affidavit,J11 23, 24.

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44. ~ Procurement of diesel generator components will

- continue to'be conducted in accordance with the requirements of 10 C.F.R.-Part 21. M. , 1 22.

45. All PNPP Nonconformance Reports written against the diesel generators have been reviewed for reportability to the NRC. - M ., 1 25. Significant conditions have been reported via Deficiency Analyses Reports ("DARs"). Id., 1 26. Of the 19 DARs

. forwarded to the NRC relating to TDI-supplied equipment, corrective' action has been completed on all but the most recent one, and the_ majority have been closed out by the NRC staff. Id.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: # " > * '

Jay E. Silberg, P.C.

Rose Ann Sullivan.

Attorneys for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000

-DATED: February 5, 1985

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