ML20108D653
| ML20108D653 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/11/1984 |
| From: | Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#484-587 OL-4, NUDOCS 8412130339 | |
| Download: ML20108D653 (300) | |
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. ygge UNITED STATES OF AMERICA
' NUCLEAR REGULATORY COMMISSION g -
Before the Atomic Safety and Licensing Appeal Board (c'c'f th31 h W :.tpy;.
M W .n BilA!O!
)
In the Matter of )
) ' *NL .
LONG' ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)-
-(Shoreham Nuclear Power Station, )
Unit 1)' )
)
)
SUFFOLK COUNTY AND STATE OF NEW YORK BRIEF IN SUPPORT OF APPEAL OF OCTOBER 29, 1984 ASLB DECISION ON LILCO'S EXEMPTION REQUEST f
Fabian G. Palomino Herbert H. Brown Special Counsel to the Governor Lawrence Coe Lanpher of the State of New York Karla J. Letsche
-Executive Chamber, Room.229 KIRKPATRICK & LOCKHART Capitol Building 1900 M Street, N.W., Suite 800
. Albany, New York 12224' Washington, D.C.
Attorney for Mario-M. Cuomo Attorneys for Suffolk County Governor of the State of New York i
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8412130339 8412il' December 11, 1984 PDR ADOCK 05000322 -
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TABLE'OF CONTENTS
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- I. . Introduction.~.c. . . = . . '.. . . . . ' . .' . . . . . . . . 1
. II . - ' Arguments . . .-. . . . . .
. . 1. .: .. . . . - . - .-. ..:. . . 4
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A.- Errors Relatingito Public Interest Finding. . . . . 8 li-; Exclusion ~'of. County and State Evidence Concerning1 Economic and Financial
' Disadvantages Resulting.from Granting Exemption, ahd' Admissionof LILCO
, Evidence ~Concerning Alleged Economic and Financial Benefits of Granting the Exemption .. .. . . . ... . . .- .. . . . . . .. 8
-2. .Exc1Usion1ofLCounty and State-Testimony Concerning Where the Public Interest Lies With Respect to the Grant of the Exemption
'and Admission: of All LILCO Testimony Concerning-the Same Issue . . . . . . . . . . . 12
- 3. Lack of. Independent Basis for Public Interest Finding.'. . . . -. . . . . . . . . . . 14 a
- , .4.- Failure to Consider' Evidence Concerning 'l Whether=There is a Need'for the Electric
- j. . Power to~be Provided by Shoreham. . . . . . . . 16
!: B.. Errors. Relating to Security Determination . . . . .- 18
- 1. Denial of Hearing on Security-Issues Arising from Proposed Change inLAC Power Configuration 1. , . . . . .. . . . . . . . 18 2., Findings Relating to Security:Without Any. Basis in' Evidentiary Record . ... . ... . 23 C. ' Errors Relating to Exigent Circumstances Finding. . :25
- l. Exclusion.of Suffolk-County Evidence Concerning LILCO's Alleged Good: Faith Attempt.to Comply with GDC 17 and Admission of LILCO Evidence cx1 the Same
. ' Subject . . .. ..-.- . . - . . . . . . . . . . . . 25 4
- 2. Improper Reliance Upon Evidence Concerning the Length and Costs tofLILCO of the z
Shoreham Licensing.Froceeding . . . . . . . . . -29 3
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- 3. Improper Consideration of Prior Staff Practices as Basis for Finding Exigent Circumstances to Support Exemption. . . . . . . 31 D. Errors Relating to the As Safe As Determination . . 32
. l' . Exclusion of Suffolk County Testimony Which Demonstrated that Operation With the Alternate AC Power Cv.afiguration Would Not Be As Safe As Operation With a Fully Qualified On-Site Power System, and Admission of All Evidence Submitted by the Staff and LILCO Concerning the "As Safe As" Comparison . . . . . . . . . . . 32
- 2. Improper Application of Commission's As Safe As Standard . . . . . . . . . . . . . . 36
- 3. Improper Consideration of Offsite Power System. . . . . . . . . . . . . . . . . . . . . . 42 E. The September 5 Phase I and II Miller Boa'rd Order Violates the Commission's Rulings and Regulations . . . . . . . . . . . . . . . _ . . . . .. 43 F. Miller Board's Issuance of a Low Power License Violates Section 50.57. . . . . . . .. . . 57 Attachments Attachment 1 Pages 41-47 of Testimony of Messrs.
.Madan and Dirmeier Attachment 2 Testimony of Richard Kessel, Chairman of the State of New York Consumer Protection Board Attachment 3 Testimony of Messrs. Hubbard and Bridenbaugh Attachment 4 Testimony of Messrs. Weatherwax and Minor
-ii-
- _ y TABLE OF AUTHORITIES-
. CASES-Aberdeen & Rockfish-Co. v. United States 565 F.2d 327 (5th Cir. 1977) . - . .. . . . . . . . . . 18 Amos Treat & Co. v. SEC, 306 F.2d 260 (D.C. Cir. 1962) . . . . . . . . . . . . . 7 Carnation Co. v. Secretary 6f Labor, 641 F.2d 801 (9th Cir. 1981) . . . . . . . . . . . . . 8
~
Cotter v. Harris, 642 F.2d 700 (3d Cir. 1981) . . . . . . . . . . . . . 18 Courts v.-Economic Opportunity Auth.,
451 F. Supp. 587 (S.D. Ga. 1978) . . . . . . . . . . . 5 Cuomo v. NRC, Civil Action No. 84-1264, Nuclear Reg. Rep. (CCH)
- 1 20,304 (D.D.C. 1984) . . . . . . . . . . . . .-. . . 5, 7 Fitzgerald v. Hampton, 457 F.2d 755 (D.C. Cir. 1972). . . . . . . . . . . . . 7 Great Lakes Screw Corp. v. NLRB, 409 F.2d 375 (7th Cir. 1969) . . . . . . . . . . . . . 18 Hupart v. Bd.-of Higher Ed. of City of New York, 420 F. Supp. 1087 (S.D.N.Y. 1976). . . . . . . . . .- . 5 Inland Steel Co. v. NLRB, 109 F.2d 9 (7th Cir. 1940) . . . . . . . . . . . . . . 4 Marshall v. Manzo, 380 U.S. 545 (1965). . . . . . . . . . . . . . . . . . 7 Montgomery Ward & Co. v.-NLRB, 103 F.2d 147 (8th Cir. 1939) . . . . . . . . . . . . . 4 NLRB v. Phelps, 136 F.2d 562 (5th Cir. 1943) . . . . . . . . . . . . . 4 NLRB v. Washington Dehydrated Food Co.,
118 F.2d 980 (9th Cir. 1941) . . . . . . . . . . . . . 8 Ohio Bell Telephone Co. v. Public Utilities Comm.,
301 U.S. 292 (1937). . . . . . . . . . . . . . . . . . 7
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1 N' a l
I Service v. Dulles, 354 U.S. 363 (1957). . . . . . . . . . . . . . . . . . 5 Superior Sav. Ass'n v. City of Cleveland, 501 F. Supp. 1244 (N.D. Ohio 1980) . . . . . . . . . . 5 Taylor v. Heckler, F. Supp. , No.83-398 (D.D.C. Sept. 5, 1984) . . . . . . . . . . . . . . . . 18 Union-Bag - Camp Paper Coro. v. FTC, 233 F. Supp. 660 ( S . D . !; . Y . 1964) . . . . . . . . . . . 8 United States v. 478.34 Acres of Land Tract No. 400, 578 F.2d 156 t3th Cir. 1978) . . . . . . . . . . . . . 8 Vitarelli v. Seaton, 359 U.S. 535 (1959). . . . . . . . . . . . . . . . . . 5
' ADMINISTRATIVE DECISIONS
-Connecticut Yankee, 2 AEC 393 (1964) . . . .. . . . . . . . . . . . . . . . 15 Houston Lighting and Power Co.,
(Allens Creek Nuclear Generating Station, Unit 1), ALAB-590, 11 NRC 542 (1980) . . . . . . . . . 23 Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
LBP-83-57, 18 NRC 445 (1983) . . . . . . . . . . . . . 2 Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
CLI-84-6, 19 NRC 1154 (1984) . . . . . - . . . . . . . . passim Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
CLI-84-21, NRC (1984). . . . . . . . . . . . 10, 43 Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
CLI-83-13, 17 NRC 741 (1983) . . . . . . . . . . . . . 10 Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
NRC Memorandum and Order, NRC (July 18, 1984). . . . . . . . . . . . . . . . . . . . 18, 19
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4 a Long Island Lighting Co.,
(Shoreham Nuclear Power Station, Unit 1),
NRC Memorandum and Order, NRC
~(August 20, 1984). . . . . . . . . . . . . . . . . . . 19 Long Island Lighting Co.,
.(Shoreham Nuclear Power Station, Unit 1),
ALAB-788, NRC (1984) . . . . . . . . . . . . 34 Mississippi Power and Light Co.,
(Grand Gulf Nuclear Station, Units 1 and 2),
ALAB-130, 6 AEC 423 (1973) . . . . . . . . . . . . . . 23
~ Pacific Gas 8--Electric Co.,
(Diablo Canyon Nuclear Power Plant, Units 1 and 2),
CLI-83-87, 18 NRC 1146 (1983). . . . . . . . .. . . . 56 Philadelphia Electric Co.,
(Peach Bottom Atomic Power Station, Units 1 and 2),
ALAB-216, 8 AEC 13 (1974). . . . . . . . . . . . . . . 23 Public Service Co. of New Hampshire, (Seabrook Station, Units 1 and 2), ALAB-422, 6 NRC 33 (1977). . . .. . . . . . . . . . . . . . . . . 52, 53 Shearon Harris II, CLI-74-22, 7 AEC 938 (1974). . . . . . . . . . . . . . 16-United States Department.of Energy (Clinch River Breeder Reactor Plant),
'CLI-83-1, 17 NRC 1 (1983). . . . . . . . . . . . . . . 16, 25 Virginia. Electric and Power Co.,
(North Anna Power Station, Units 1 and 2),
LBP-77-64, 6 NRC 808 (1977). . . . . . . . . . . . . . 22, 61 Washington Public Power Supply System,
-(WPPSS Nuclear Projects Nos. 3 and 5),
CLI-77-11, 5 NRC 719 (1977). . . . . . . . . . . . . . 16 STATUTES Atomic' Energy Act, 42 USC 5 2131, 5 2133, 2232, 5 2235. . . . . . . . . 54
~ REGULATIONS 10-CFR 2.717(b) . . . . . . . . . . . . . . . . . . . . . 21 m m
a r , .
10 CFR.$ 2.762. . .' '. . . . . . . . . . . . . . . . . . . . 1 10 CFR @ 2.764(g) . . . . . . . . . . . . . . . . . . . . . 43 10 CFRLS 50.~12(a) . . . . . . . . . . . . . .. . . . . . . . . passim 10 CFR 50.23. . . . . . . . . . . . . . . . . . . .. . . . 54
'10 CFR S.50.30. . . . . . .. . . . . . . . . . . . . . . . 54
-10 CFR 9 50.33. . . . . . . . . . . . . . . . . . . . . . . 54 10 CFR 5 50.47(d) . . . . . . . . . . . . . . . . . . . . . 39-10 CFR 5 50.51. . . . . . . . . . . . . . . . . . . . . . . 54 10 CFR S 50.55(d) . . . . . . . . . . . . . . . . . . . . . 54 10 CFR 5 5'0.56. . . . . . . . . . . . . . . . . . . . . . . 55 10 CFR @ 50.57. . . . . . . . . . . . . . . . . . . . . . . 55 10 CFR Part 50, Appendix A GDC 1. . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 2. . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 3. . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 4. . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 17 . . . . . . . . . . . . . . . . . . . . . . . . passim GDC 18 . . . . . . . . . . . . . . . . . . . . . . . . 58-GDC 33 . . . . . . . . . . . . . . . . . . . . . . . . 58 l
GDC 34 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 35 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 37 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 38 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 40 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 41 . . . . . . . . . . . . . . . . . . . . . . . . 58 GDC 43 . . . . . . .. . . . . . . . . . . . . . . . . . 58 GDC 44 . . . . . . . . . . . . . . . . . . . . . . . . 58
, GDC 46 . . . . . . . . . . . . . . . . . . . . . . . . 58
- 10 CFR Part 50, Appendix B. . . .. . . . . . . . . . . . . 58 10 CFR Part 73. . . . . . . . . . . . . . . . . . . . . . . .22 OTHER 47 Fed. Reg. 30,234-(1982) . . . . . . . . . . . . . . . . 37 49 Fed. Reg. 13,611-12 (1984) . . . . . . . . . . . . . . . 3 Letter dated June 15, 1984 from Nunzio J. Palladino to the Honorable Edward J. Markey. . . . . . . . . . . 34
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LNITED STATES & AMERICA NUCLEAR REGUIRIORY COMISSION Before the Atcznic Safety and Licensing Appeal Board
)
In the Matter of )
)
IONG ISIAND LIGffING COiPANY *) Docket No. 50-322-OL-4
) (Iow Power)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
)
. STEDIK COLNIY AND STATE & NEW YORK BRIEF IN SUPPORT T APPEAL T OC'ICBER 29, 1984 ASIB IECISION ON LIICO'S EXEMPTION REQUEST
'I . INTROIXETION Pursuant to 10 CFR { 2.762, this Brief is sutrnitted in support of the ap-peal by Suffolk County and the State of New York of the Initial Decision issued by the Licensing Board chaired by Marshall Miller (" Miller Board") on October 29,1984 (LBP-84-45) (hereinafter, the " Decision") . 'Ihe Decision at issue rec-cmnended approval of two LIICO requests: (1) its request for an exemption frcan ecmpliance with the NRC's regulations tzxler 10 CFR { 50.12(a); and (2) its re-quest for a low power license. Ebr the reasons we detail below, the Miller Board erred in reccmnending approval of those LIICO requests.
LIICO's need for an exemption arises frcan its inability to ccruply with the
- requirenents of 10 CFR Part 50, GDC 17. 'Ihat criterion requires that there be an on-site electric power system which, assuning the off-site electric pwr system is not functioning, has sufficient capacity and capability to assure the functioning of structures, systems and ccmponents important to safety.
According to GDC 17, such an on-site electric power system nust also have
s ,
sufficient independence, redundancy and testability to perform its safety function asstaning a single failure.
The Shoreham plant was designed to incitrie three emergency diesel genera-tors manufactured by TransAmerica Delaval, Inc. ("TDI") to cmprise the on-site source of AC power. However, following failures of those TDI diesels during preoperational testing and the admission for litigation of contentions concern-ing the adequacy of the TDIs, the Brenner Licensing Board ruled that no low power license could be issued for Shoreham until LIICO had established in the TDI litigation that the TDIs emplied with all applicable regulations and Shoreham design requirements. See Iong Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), IBP-83-57,18 NRC 445, 634 (1983); Tr. 21,615 (Brenner) .
Subsequently, the Om mission ruled on May 16, 1984 that in order to obtain a low power license prior to ccmpletion of the TDI litigation pending before the Brenner Board, LIICO nust satisfy the requirements necessary to obtain an exemp-tion frcm the regulations under 10 CFR 50.12(a). See Iong Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1), CLI-84-8, 19 NRC 1154 (1984) (herein-after, "May 16 Order") .
LIICO has proposed that it be permitted to operate Shoreham at up to 5 per-cent of rated power using an alternate AC power configuration in place of the TDI diesels. 'Ihe proposed alternate configuration consists of a set of four no-bile diesel generators manufactured by the Electrcmotive Division of General Motors (the "EMDs") which are sittirg on railroad ties next to the plant build-ings, and a .70 MW gas turbine which sits in the 69 KV switchyard near the plant.
LIICO asserted that through the use of the EMDs and/or the gas turbine, emergen-cy AC power could be supplied in the event that a loss of offsite power occurred p ,-- y - y-d a+ s-&e, . - --- - - - - . --v -
I e during lw power operation. See LIICO's Application for Exenption, May 22, 1984.
. After having. established the Miller Board to deal with LIIID's lw power license request (see 49 Fed. Reg. 13,611-12 (1984)), the Ctanission set forth the particular determinations which the Miller Board was required to make in ruling upon LIICO's exeuption application. In its May 16 Order, the Ccanission held that in addition to the determinations expressly set' forth in Section 50.12(a) itself (i.e., that the exemption (1) is authorized by law, (2) will not endanger life or prcperty, (3) will not endanger ccmnon defense and security, and (4) is otherwise in the public interest), LIIf0 also had to denonstrate that: (a) there exist exigent circunstances that favor the granting of an exenp-tion; and, (b) cperation at up to 5 percent power m uld be as safe under the alternate power configuration proposed by LIICO, as operation would have been with a fully qualified on-site AC power source. 19 NRC at 1155-56. '1he legal .
errors ccmnitted by the Miller Board during the course of the exemption proceed-ing enabled that Board to make each of those findings desired and needed by LIICO to obtain a license. 'Ihus, as a direct result of the due process viola-tions ve detail belw, the Miller Board found that LIICO had demonstrated that granting the exemption would be in the public interest; that granting the exenp-tion muld not endanger life, property, or the cmanon defense or security by giving rise to any physical security risks; that exigent circunstances exist that favor granting the exemption; and that lw power operation of Shoreham under the alternate configuration proposed by LIICO would be as safe as operation would have been with the fully qualified TDI diesels. Each of these findingswaserroneousandmustbereversedbythisAppealBoard._1/ l l
lj '1he detailed position of Suffolk County and the State of New York concern-ing the LIIf0 exemption request (on i.ssues other than the denial of securi- l (Footnote cont'd next page)
e .
II. AIEMENI'
'Ihe Miller Board Decision which recumierds approval of LIICO's exemption request nust be sumarily reversed because the fundamental due process rights of Suffolk County and the State of New York were irremediably violated in the course of the " proceeding" conducted by the Miller Board. 'Ihus, although sme testimony was accepted into an evidentiary record, sme cross examination and argment of counsel were permitted, and briefs were accepted purportedly on the issues identified in the May 16 Order, in fact what occurred during the exemp-tion proceeding did not constitute a fair hearing at all. It was merely a vehi-cle by which the Miller Board itself became an advocate for LIICO's self-interest. In pursuing that advocacy, the Miller Board abused the NRC hear-ing process and trounced upon the fundamental constitutionally protected rights
, of the Intervenors. See NLRB v. Phelps, 136 F.2d 562 (5th Cir. 1943); Inland Steel Co. v. NIRB,109 F.2d 9 (7th Cir.1940) (petitioner denied full and fair hearing where trial examiner limited scope of cross examination, and conducted l ,
coercive examination of witnesses, becming advocate); Montgmery Ward & Co. v.
f (Footnote cont'd frm previous page) l - ty contentions) is set forth in the following filings with the Miller Board: the Suffolk County and State of New York Proposed Finlings of Fact (hereinafter, " County and State Findings"), the Brief of Suffolk Cbunty in Opposition to LIIf0's Motion for a 104 Power Operating License and Applica-tion for Exemption, and the Brief of the State of New York in Opposition to l
l LIICO's Application for a Iow Ibwer Operating License on the Basis of an Exemption frm the Regulations Pursuant to 10 CFR $ 50.12(a), all dated August 31, 1984; Suffolk County and State of New York Memorands in Opposi-tion to LIICO's May 22, 1984 Motions for Summary Disposition on Phase I and Phase II of LIICO's Proposed "Iov Power Testing," dated June 13, 1984; and Suffolk County and State of New York Views on Why the ASIB's September 5 Order May Not Serve as the Basis for Phase I and II License, dated Septenber 14, 1984.
l l
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. o NIRB,103 F.2d 147 (8th Cir.1939) (due process denied where trial examiner "assuned the place of. attorney supparting the emplaint," placed unfair restric-tion on examination of witnesses, and mitted frm the record occurrences at the
-hearing).
'Ihe fundamental due process right to a fair hearing was enphatically ramm4=A by the Iktited States District Cburt in its April 25, 1984, decision which enjoined the previous attempts by the Miller Board to conduct a proceeding in violation of the Constitution. See Cumo v. NRC, Civil Action No. 84-1264, I Nuclear Reg. Rep. (CCH) 120,304(D.D.C.1984).2/ While the U.S. District 3
Court's April 25 Tertiporary Restraining Order against the NRC and the Miller Board put an end to the first showing of regulatory abuses, the exenption pro-ceeding which follev.ed proved that the past was just prologue. 'Ihe Miller Board pursued a pattern of behavior'which included a series of errors of such nature as to deny the County and State procedural and substantive due process guaran-teed by the Fifth Amendment to the U.S. (bnstitution, the Atmic Ehergy Act, the Administrative Procedure Act, and the Ocmnission's own Rules of Practice.3/ 'Ihe
-2/ In addition, the necessity for a fair hearing was recognized by the Comis-sion in the May 16 Order, which required that the Licensing Board "shall conduct the proceeding . . . in accordance with the Ocmnission's rules."
19 NRC at 1156.
For the reasons detailed in this Brief, it is clear that the Miller Board
-3/
I' failed to follow the NRC's rules in conducting the exemption proceeding.
l This failure constitutes an independent basis for finding a due process vi-olation. See Vitarelli v. Seaton, 359 U.S. 535 (1959) (denial of due pro -
l cess for any goverment agency not to follow its own regulations pertaining to adjudication processes); Service v. Dulles, 354 U.S. 363 (1957) (admin-istrative agency bound to observe its own regulations and denies due pro-cess if it does not). See also Superior Sav. Ass'n v. City of Cleveland, 501 F.Supp.1244,1249 (N.D. Olio 1980); Courts v. Econmic Opportunity Auth., 451 F.Supp. 587, 592 (S.D. Ga. 1978); Hupart v. Bd. of Higher Ed. of City of New York, 420 F.Supp.1087,1107 (S.D.N.Y.1976) (agency's failure
- to " scrupulously observe" rules, regulations, or procedures it has established may in and of itself constitute due process violation).
i l.
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Miller Board's denial of the Intervenors' due process right to u fair hearing led directly to the Board's rulings, in LIICO's favor, with respect to each of the specific determinations identified in the regulations and by the Ocnnission
~ as being' prerequisites to the grant of an exemption.
, 'Ihe most blatant of the Miller Board's denials of due process was its re-peated pattern of refusing to admit evidence submitted by the County and the State on issues articulated by the Otznission in its May is Order, with acccupa-
~
nying rulings that-LIICO and Staff evidence on precisely the same. issues was ad-missible.4/ Each of these rulings was made by the Miller Board at LIIf0's re-
! quest. 'lhis denial of the ftmdanental right to subnit evidence on the central i
matters at issue was made even more prejudicial by the Miller Board's sobaagaent reliance upon the one-sided LIICO and Staff evidence to make the findings neces- .
sary to support r.Tren's exenption request.
'1he Miller Board also made findings relating to the adequacy of LIIf0's se-
- curity plan to Irotect the Iraposed alternate AC power configuration. Such
. findings are ' required by Section 50.12(a) and the Ocmaission's July 18, 1984 Memorandtzn and Order. However, there was absolutely no. basis in the record for
,a ny such findings since the Miller Board had violated Ctanission guidance and refused to permit litigation of security contentions subnitted by New York and Suffolk County, the admissibility and the substantive accuracy of dtich, in ma-terial part, were supported by the NRC Staff. 'lhus, without having conducted an ;
i' 4/ As we describe in detail below, this consistent Miller Board denial of the Intervenors' rights occurred with respect to the issues of whether the pub-lic interest favors the exemption, whether exigent circumstances exist, and whether operation with the alternate configuration proposed by LIILO would be as safe as operation with a fully qualified source of AC power.
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evidentiary proceeding (nuch less having admitted security contentions), the Miller Board could not possibly have made any security findings. Yet that is precisely what it did.
'Ihe Miller Board also refused to consider matters which the Ccmmission's own Section 50.12 precedents and its May 16 order identify as key considerations in exemption decisions, its ruling on Phases I and II violated the Ocmnission's rulings and the NRC's regulations, and it made clearly erroneous rulings on other legal and factual issues.
'Ihese errors, all discussed in Sections II.A. through II.F below, consti-tute a denial of a fair hearing which must be recognized and renedied by this Board. A fair trial before a fair tribunal is a basic requirement of due pro-cess. Fitzgerald v. Hampton, 467 F.2d 755, 764 (D.C. Cir. 1972). '1his Board cannot close its eyes to the gross deprivation of rights which has been permit-ted to take place. Due process requires the resolution of contested questions by an impartial and disinterested tribunal in a fair proceeding. Amos Treat &
Co. v. SEC, 306 F.2d 260, 263-64 (D.C. Cir.1%2) . As both the Amos Treat Court and the U.S. District (burt in the NRC TRO case held:
[A]n administrative hearing of sida importance and vast potential consequences must be attended, not : r.ly with every elenent of fairness but with the very appearance of ecmplete fairness. Only then can the tribunal conducting a quasi-adjudicatory proceeding meet the basic requirements of due process.
l Cucmo v. NRC; supra, slip op. at 5, citing Amos Treat, 306 F.2d at 267. See i
also Marshall v. Manzo, 380 U.S. 545, 552 (1965) (due process requires that par-i ties be afforded the opportunity to be heard "at a meaningful time and in a meaningful manner"); Chio Bell Telephone Co. v. Public Utilities Ocnn., 301 U.S.
i 292, 304-05 (1937) (right to fair hearing is "one of the ' rudiments of fair i
L . - _ .
play' . . . assured to every litigant by the Eburteenth Amendment as a minimal requirement"); Carnation (b. v. Secretary of Iabor, 641 F.2d 801 (9th Cir.1981)
(procedural due process requires that a party against whcm an agency has proceeded be allowed to rebut evidence offered by the agency if that evidence is relevant); United States v. 478.34 Acres of Land Tract No. 400, 578 F.2d 156 (6th Cir.1978); NIRB v. Washington Dehydrated Ebod (b.,118 F.2d 980 (9th Cir.
1941) (due process requires a tribunal both impartial and mentally ccupetent to afford a hearing); Union Bag - Camp Paper Corp. v. FIC, 233 F. Supp. 660, 666 (S.D.N.Y. 1964) (agency action denying party the right to present its evidence and sumen the witnesses of its choice violates the constitutional right of due process of law as well as the concept of fairness necessary to every proceed-ing). We demonstrate belcw that the Miller Board's conduct of the exemption proceeding violated these basic due process principles.
A. Errors Relating to Public Interest Finding
- 1. Exclusion of County and State Evidence Concerning Econanic and Financial Disadvantages Resulting fran Granting Exemption, and Admission of LIICO Evidence Cbncernirvy Alleged Eccmcmic and Financial Benefits of Granting the Exenption 10 CFR i 50.12(a) requires that before an exenption frcm the requirements j in the NRC's regulations can be granted, the Ocnnission must determine that the l
exemption will not endanger life, property, or the comon defense and security, and that the exemption is "otherwise in the public interest." (emphasis supplied). LIICO asserted there were at least two public benefits of icw power operation follcwing the granting of an exemption which the Miller Board should I
i consider as exigent circunstances weighing i~n favor of granting the exemption:
(1) the reduction in dependence on foreign oil; and, (2) certain ecenanic benefits to LIICO ratepayers.5_/ Both these alleged public interest " benefits,"
l 5/ In its Application, LIICO ime.vyerly linked the exigent circumstances find-ing required by the Ccnnission with the "otherwise in the public interest" (Footnote cont'd next page)
L
_ft
/
according to LIICO,' would be achieved when Shoreham begins full power operation.
See Application for Exemption at 15-16,20-21.6./ LIICO submitted testimony to the Miller Board which discussed these so-called benefits. See Tr. 1336-43, 1402-10. Se LIICO testimony, however; did not deal with any benefits which could result fra the conduct of low power testing, which is what would be au- !
thorized by the exatption; rather; it dealt with possible benefits which could result only if it were assmed that full power operation of 3horeham would even-tuallyoccur.7/
(Ebotnote cont'd frm previous page) i
! finding expressly mandated by Section 50.12(a). See, e.g. , Application for Exemption at 15-16. As we discuss in Section II.X 1 below, the Miller Board.did the same thing - it failed to make an independent public inter-est finding, despite the fact that the Cats::ission made clear that the exi-gent ciretanstances finding represents a threshold that an exemption appli-cant must meet separate frm; and in addition to, the requirenents set
- forth in Section 50.12(a). See 19 NRC at 1156, n.3, and discussion in Sec-4 tion II.C.1 below. In its Bost-Trial Brief, LIICO argued that these two alleged " benefits" related to the required public interest finding. See ,
LIIf0's Post Hearing Brief in Support of Application for Exemption, at 58-66. Even though the Miller Board nonetheless considered the possibility j that the " benefits" alleged by LIIID would be achieved as consituting "exi-
! gent circumstances" (see Decision, at 60-63), we discuss them here since I
purportedly, they would constitute " benefits" to the general public.
6/ hus, reducing dependence upon foreign oil cannot occur until after a full power license is issued to Shoreham, the plant has been tied into the LIIf0 grid, and it begins to produce electricity in camercial operation. See,
_e.g., Tr. 1235-36, 1249-50, 1330. Similarly, the alleged ratepayer " bene-fit" which, according to LIIDO, would be received by the public in 1997
! fr m beginning caumercial operation three months earlier than would be pos-sible without an exerrption, can only cane into being after cartnercial full power operation begins and Shoreham goes into LIICO's rate base. See, eg ., Tr. 1372, 1405-10.
7/ Re (bunty and the State moved to strike such testimony as irrelevant and
- speculative because it did not deal with " benefits" which muld accrue as L the result of the grant of the exenption - the matter at issue - nor would such benefits even materialize tritil after the plant achieved full power operation. S e Miller Board denied those motions. See Tr. 1237-68, 1356.
( .
. .3 he County submitted testimony concerning the substantial financial and econanic harm to the public that would result fra the grant of the exemption if the assunption that is the converse of LIICO's - i.e., that there would be no full power operation of Shoreham - was a premise for evaluating the public in-terest. At- LIICO's urging (see Tr. 2122-23), the Miller Board refused to accept 1'
such evidence. M us, the County's testimony W ich discussed the economic penal- ,
ties to the' public which would result fran contaminating Shoreham to perform ' low power testing asstaning that authorization for full power operation did not fol-low was not admitted by the Miller Board. See Tr. 2145-48.8_/
According to the Q2mnission's own statements, the asstanption that full e
power operation of Shoreham will never be achieved is at least as appropriate as - [
i the opposite asstaption Wich is preferred by LIICO and which was adchted by the
. Miller Board. Sus, in its Novenber 21, 1984 Memorandtsn and Order (CLI-84-21),
i the Ctmunission expressly rejected the suggestion that "once a Phase I and II li-cense is granted, the eventual issuance of a full power license is a foregone ,
_ conclusion." Iong Island Lighting Co. (Shoreham Nuclear Power Station, thit 1),
CLI-84-21, NRC (1984) (slip op. at 5).9/ here was no basis, there-fore, for the Miller Board's refusal to consider evidence prenised on the 4
I Of A copy of the referenced portion of Messrs. Madan and Dirmeier's testimony (that is, pages 41-47), Which was among that stricken by the Board, is At-tactsnent 1 hereto.
-9/- See also Iong Island Lighting Co., (Shoreham Nuclear Pbwer Station, thit 1), CLI-83-13,17 NRC 741, 744 (1983) (separate views of Canmissioner Gilinsky) ("here cannot be adequate emergency preparedness for surrounding population without the participation of a responsible government entity.
l And, however they may qualify their views now, I do not believe that a sin-gle Ctmunissioner would actually approve the operation of the plant without such participation.") (emphasis added).
i t i
I
. - . - - - . , - - _ . . - , - - . . - ~ ~ - - - . . _ , - _ _ _ _ _ _ _ _ _ - . - . . , , . - . - ~ . - , - - - . ,
I e .
3 1
asstaption proferred by the County, since Shoreham's not obtaining a- full power
.e license is at least as probable as the converse asstaption proferred by LIICO h and adopted without question or explanation by the Miller Board. L he prejudice resulting frcm the Miller Board's admission of MICO's testi-
{- many ce.couing alleged econcmic benefits of the exeruption and its refusal to f- admit the Oxmty testimony based on the converse asstmption, is manifest in the f
l Board's Decision. '1he Board's rulings ce.cerning alleged financial and oceanic
. hardships rely only upon testimony stimitted by LIICO. See Decision at
- i
{.
60-63.10/ Moreover, the specific findings ce.cm uing alleged possible fuel sav-j- .ings, reduced dependence on foreign oil, and possible benefits to ratepayers,
!' 'are all hanM solely upon the LIIWoffered asstaption of eventual full power 10] Richard Kessel, the Chairman of the State of New York Constner Protection Board, whose job it is to represent the constaners of the State of New York,
, stimitted testimony on behalf of New York. A copy of his testimony, marked -
} to reflect the Miller Board's rulings (see Tr. 2893-908), is Attactnent 2 hereto. As can be seen, much of it was stricken by the Board in response i- to LIICO's motions (see Tr. 2893-908), but sentences stating that it is not i j' in the pit >lic interest to contaminate a nuclear facility before i . uncertainties surrounding its future operation have been resolved, and that "
1 if Shoreham were operated at low power and subsequently were abandoned, the costs that ratepayers would ultimately bear would be increased, were
- - (inexplicably, in light of its other rulings) let in by the Board. . LIICO argued that Mr. Kessel's testimony should be disregarded because it a s in-
- carpetent and not supported by any facts. See, e g , Tr. 3104-105; LIICO's -
l Post-Hearing Brief in Fupport of Application for Exeimption, at 54. 'Ihe j- Cotmty testimony stricken by the Miller Board provided substantial factual support for Mr. Kessel's more stamary testimony, and'Mr. Kessel expressly
~
referenced the County's witnesses in his testimony. See Tr. 2145-48 and
- Attactment 2 hereto. Consistent with LIICO's suggestion, however, the Miller Board's Decision fails even to acknowledge the existence of Mr. ,
Kessel's testimony on this matter of the public interest. See Section l
{ II.A.2 below. 'Ihe one citation to Mr. Kessel's oral testimony (see last '
} transcript citation in n.125 in Decision) is incorrect; Mr. Kessel's state- i i ment does not support the Board's assertion, for which it is cited, that t there would be fuel savings or reduced dependence on foreign oil as a re- '
sult of granting LIICO's exeription request.
i 4
o 1 [
j -
~ , - _ . - . . , - . . . _ - _ . _ _ - - . . - _ . . . _ . _ , _ _ _ . _.-. _ _ _ _ _ , . , _ _ .
1 operation. Id. at 61. Se fact that only such one-sided evidence, and only the asstatption favorable to LIICO, was considered by the Miller Board in its finding concerning the econanic inpact on the public of the requested exenption consti-tutes clear error and the denial of a fair hearing.
Similarly, the Miller Board's reliance in the Decision upon LIICO's testi-many about the relationship between the issuance of a license and its own pri-i vate financial needs was also clearly erroneous. h us, the Board apparently ac-4 cepted as "an equity" weighing in favor of the exenption, the LIICO testimony that "the granting of a low-power exenption would send a positive signal to the capital markets that would help to alleviate f. Tim's financial distress in ob-taining vitally needed cash by the issuance of securities." Decision at 61.
his Board cannot countenance such a clearly inproper atterpt by the Miller Board to base, even in part, a decision to permit the operation of a nuclear
- power plant upon a perceived need to " send a signal" to the capital markets on LIICO's behalf.
- 2. Exclusion of County and State h atimony Concerning Where the Public Interest Lies with Respect to the Grant of the Exenption, and Admission of All LIICO Testimorrf Concerning the Same Issue
, Although LIIDO was pennitted to subnit testimony concerning LIICO's view of the public's interest, the Miller Board refused to admit evidence submitted by the actual elected representatives of the public - the Governor of New York and Suffolk County - which would have set forth several reasons Why it is not in the p@lic interest to grant an exeiption to LIICO. %us, Suffolk County sub-mitted testimony which discussed the inpact upon electrical service to LIIro's custmers which muld result frm the exemption, and New York subnitted
s testimony that the electrical power fran Shoreham is not needed for at least ten years. See Attachments 1 and 2. Similarly, as discussed in Section II.A.1 above, the County subnitted testimony concerning the econcmic harm to the public that could result if the exenption were granted, resulting in contamination of the plant, but if a full power license were not subsequently issued, as LIICO assuned. At LIICO's urging, none of this evidence was admitted by the Miller Board. See Tr. 2122-23, 2145-48, 2902-903.
It cannot be disputed that the public servants who were denied the right to present evidence are in a far better position to advise the NRC regarding where the public interest lies than LIICO. Indeed, a year ago, in the Ocunission's brief before the U.S. Court of Appeals in a case involving the Diablo Canyon plant, the Ccmnission argued for the legitimacy of its action by citing the
" great weight" it gives to the views of a State government:
Finally, the Supreme .Cburt has noted that the debate over nuclear power is one in which the States have a vital stake.
[ Citing Vermont Yankee.3 In this case the Governor of California, as representative of the people and the public inter-est, has indicated in hearings before the' Appeal Board that he does not oppose this action. %e views of the chief elected rep-resentative of the people of California should be accorded great weight in fixing where the public interest lies.
NRC Brief, page 34 (emphasis supplied, citations onitted). In the Diablo case, I the Governor of California had supported the NRC's action reinstating a license for the plant. Here, in the Shoreham case, the chief elected representative of the people of New York and the elected goverrynent of the people of Suffolk Coun-ty oppose issuance of a low power license, and they subnitted testimony as to why such an action by the NRC would be contrary to the public interest. The Miller Board not only refused to give such testimony " great weight" as the
Ccanission did in pleading before the Court of Appeals, but at LIICO's urging, it refused to consider such evidence at all.
'Ihe Miller. Board's reliance upon LIIro's purported public interest testimo-ny (see Decision at 60-63), and its refusal even to consider the testimony sub-mitted by the Governor, representing the millions of residents of the State, and _
suffolk County, Which has 1.3 million residents, whose obligation and responsi-bility it is to serve and rotect I the public who have elected them, constitutes clear error. It also constitutes a denial of the State's and County's due pro-cess right to a hearing on this issue sich is central to the granting of an ex ,
emption under Section 50.12(a).
- 3. Iack of Independent Basis for Public Interest Finding
~
The Miller Board concluded that LIICO's Exenption Application " meets the
'otherwise in the p@lic interest' provision of 10 CFR $ 50.12(a)." Decision at 104,16. ' mat " conclusion," however, by the Board's own admission, is solely
"[r]ased upon [the Board's] finding that the Application for Exenption meets the
' exigent ciretznstances' test set forth by the 0:mmission," (id_.); and, that
,' finding, in turn, is based solely upon the Board's so-called " balancing of the equities" and its finding that "the Application and evidence adduced in support thereof denonstrate the ' exigent ciretmstances' that favor the granting of an exemption . . . ." Id. at 103, t 5.l_l] 'Ihis wholly circular analysis is devoid of any stbstantive content or basis in logic or fact, and nust be rejected.
,l_1/ As noted in Section II.A.1 above and Section II.C.1 below, the exigent cir-cumstances finding and so-called " balancing" of equities were based solely upon LIICO's evidence concerning purported " benefits" which would result frcm eventual full power operation of Shoreham, and purported efforts of LIIDO relating to the TDI diesels. W e County and State evidence on these matters was Tt admitted.
Were is no support in Ctmnission precedent, nor did the Miller Board cite any, for the Board's tortured reasoning that meeting an exigent ciretanstances test established by the Ctenission, autanatically satisfies the wholly separate Sec-tion 50.12(a) requirement that an exenption "otherwise" be "in the public inter-est." Ebrthermore, the Miller Board's treatment of the public interest findinJ required under Section 50.12(a) violates Connecticut Yankee, 2 AEC 393 (1964),
which held that the public interest determination " constitutes a distinct and separate aspect" of an exemption decision. Id. at 394, n.1.
In fact, the "public interest" is mentioned only twice in the Decision: in the one-sentence " conclusion of law" in piragraph 6 on page 104 which is cited above, and in a six-sentence section tmder " Exigent Circumstances" which is headed "Public Interest in Adherence to Regulations." he discussion in that section of the Decision, however, makes no reference to any of the evidence which the County and State subnitted or atterpted to submit concerning the actu- .
al interests of the public living in Suffolk County and New York State concern-ing the exenption. See Decision at 68-69. Ebr that matter, it also makes no reference to any LIICO evidence concerning the alleged public interest. In-stead, it references the "denonstrated safety of low power testing as proposed" by LIIro, the general principle that administrative agencies have the authority to provide for exeiption procedures, and the Board's public health and safety findings. It concludes, without citation to any evidence, that "there is mini-mal public interest in strict or mechanical adherence to the regulations."
_Id.12/ Wus, in actual fact, and as the Decision itself makes clear, the Miller
-'-12/ W e Miller Board's circular reasoning that its health and safety findings establish the basis for a public interest finding again violates Connacticut Yankee, which held that the public interest determination is (Footnote cont'd next page)
Board never even considered the interests of the public with respect to the LIIDO exetption requestr rather, it considered only the one-sided " evidence" which dealt with r. Tim's interests in sigrmiling the capital markets and in ob-
'taining a full power license. hus it had no basis in the record for making the "otherwise in the p @ lic interest" finding required tmder Section 50.12(a).
- 4. Failure to Consider Evidence Gramuing mother here is a Need for the Electric Pbwer to be Provided by Shoreham At LIID0's request, the Miller Board refused to admit New York testinony Which established that there is no need for Shoreham's power for at least 10 years and perhaps longer. See Tr. 2902-03. Omnission Irecedent makes clear, however, that the need for power is very relevent to decisions on exerption re-quests. See United States Department of h ergy (Clinch River Breeder Reactor Plant), CLI-83-1, 17 NRC 1, 4 (1983); Washington Public Power Supply System (WPPSS Nuclear Projects Nos. 3 and 5), CLI-77-ll, 5 NRC 719 (1977).l3,/ In di-rect conflict with this legal authority, however, the Miller Board struck the New York testimony on'the question of the need for electric power. See Tr.
i ,' 2903. We Board's refusal to consider Whether there is any nee $ for the power i
to be supplied by Shoreham was clearly erroneous, and the prejudicial impact of this ruling was substantial.
i (Footnote cont'd fran previous page) i not intended to be a repetition of the factors considered in making the health and safety findings. 2 ABC at 394, n.1.
l3/ he Miller Board appears to acknowledge the significance of this fact by its citation of Shearon Harris II, CLI-74-22, '7 Al!C 938 (1974), which it quotes as holding that "the timely satisfaction of public needs by reducing
, unanticipated delays in the realization of facility benefits . . ." consti-1 tutes an exanple of an exigent circumstance. Decision at 58.
i i
4 i
e e First, the fact that Shoreham's power is not needed for at least 10 years.
totally obviates the need for the exemption requested by LIICO, which has
-resulted in the mprecedented rush to license Shoreham by means that violate the parties' constitutional rights and defy logic and reason. Because there is no need for Shoreham's electricity, there is sinply no need to dispense with the
- normal' NRC requirement that LIICO caply with safety regulations before a li-i censeisissued.l_4/ 'Ihus, the fact that there is no need for Shoreham's per for at least 10 years is dispositive of LIICO's exeiption request. In refusing-to consider evidence on this subject, therefore, the Miller Board not only ig-I nored Omnission precedent but also ignored clearly dispositive evidence.l5_/
} -
i second, the Miller Board's reliance upon LIICO's evidence concerning '
i so-called " benefits" of bringing Shoreham into full power - a speculative con-t clusion Wiich asstanes the existence of a need for the power (as well as the
{ eventual issuance of a full power license) - substantially increases the preju-l dice resulting fr m its refusal to admit Intervenors' evidence concerning the i
- absence of need for that power. '1hus, this Miller Board ruling is yet another exanple of the Board's consistent pattern of considering and relying upon i
14/ Moreover, the fact that Shoreham's electricity is not needed means that the only logical and reasonable course of action - resolving the uncertainties l relating to emergency planning before any contamination of the reactor -
! can be followed without any adverse inpact on the provision of electricity to Iong Island.
1_5/ 5 'Ihe fact that anple LIICO generating capacity exists to satisfy probable demand for at least 10 years was contained in an exhibit which was admitted i
into evidence. SC LP Ex. 20. However, it is clear fra the Miller Board's Decision and frcm its ruling that the evidence concerning the need for electric power in Mr. Kessel's testimony was inadmissible, that the Miller
- Board failed to consider at all these tmdeniably significant data in
- granting LIICO's exernption request.
i, l
t I
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evidence which favored LIIID's position and ignoring any evidence which could point to a result other than one in LIICO's favor.l6/
B. Errors Relating to Security Determination
- 1. Denial of Hearing on Security Issues Arising frm Proposed Gange in AC Pcwer G nfiguration The Cournission has recognized that physical security issues are pertinent t.o the granting of an exemption. See Iong Island Lighting Co. (Shoreham 1A2 clear Power Station, Unit 1), NRC Manorandtan and Order, NRC (July 18, 1984) (slip op. at 2-3, and n.1). That Order was issued in response to the County / State motion for directed certification of a June 20, 1984 Miller Board Order diich precluded Intervenors frm raising any physical security issues..l.7/
1_6/ nandamental due process requires an administrative agency, in issuing an order, to make a reasoned analysis based on adequate findings-supported by substantial evidence in the record. See Cotter v. Harris, 642 F.2d 700, 706-07 (3d Cir.1981) (administrative judge cannot reject evidence for no reason or for wrong reason; an explanation why probative evidence has been rejected is required); Aberdeen & Ibckfish (b. v. tkiited States, 565 F.2d 327, 334-35 (5th Cir.1977), rev'd on other grounds sub nczu, Iong Island Ry. Cmpany v. Aberdeen & Bbckfish Ry. Ocnnpany, 439 U.S. 1 (1978), modified
,' sub non, Aberdeen Bbckfish Ry. Ocznpany v. United States, 586 F.2d 609 (5th Cir.1979); Great lakes Screw Corp. v. NLRB, 409 F.2d 375, 379 (7th Cir.
1%9); Taylor v. Heckler, F.Supp. , No.83-396 (D.D.C. Sept. 5, 1984).
_1_7,/ As the Ocmnission recognized, the County ard State sought to raise the fol-lowing issues before the Ocnnission:
Is a showing that a requested exernption frm the NRC's regulations will not endanger the ccmnon defense ard securi-ty required in order to obtain an exemption under 10 CFR
{50.12(a)7 Is evidence relating to such a showing by LIICO rele-vant and admissible in the proceeding to b'e held on LIICO's Application for Erenption7 July 18 Order at 2, n.l. The Ocmnission observed that while "it is not at all clear that a physical security (sabotage) issue involving a light water (Footnote cont'd next page)
+
W
,: . 'Ihe Omnission also recognized that LIICO's exemption application " represent [ed]
. .a new developnent in this proceeding, and it raise [d] some new issues not here-tofore considerod." 3..at 2. Furthermore,- the Omnission later stated that in issuing-its ally 18 Order, it had "specifically considered the full text of the 1982 settlement agreement" between LIIDO 'and Suffolk County relating to LIIDO's
. then existing security plan. Iong Island Lighting (b. (Shoreham Nuclear Power Station,1thsit 1), NRC Memorandum and Order, NBC (August 20, 1984) '
(slip op. at 2). In its July 18 Security Order, the Qmission held that the t
parties "were to be afforded the opporttmity to raise new contentions, so long as' they were responsive to new issues raised by LIIDO's exmption request, rele-I vant to the exemption application and decision criteria cited and explained in the May 16, 1984 Order, and reasonably specific end otherwise capable of on-the-record litigation." July 18 Order at 2-3.
Suffolk Cotmty and the State of New York submitted seven detailed conten-tions concerning the security issues raised by LIIro's exmption proposal.18/
-(Footnote cont'd fran previous page) b ,>~'
power reactor is cognizable as a 'comon defense arx1 security' concern,"
that was "only an academic legal point, since a light water power reactor -
physical security issue is, in any event, cognizable as a public health and safety concern or, using the language of the standards for exemptions in 10 CFR 50.12(a), a concern bearing on whether the exemption will ' endanger life or property.'" M.
- ,18/ Due to safeguards considerations, we do not discuss the details of those contentions in this pleading, but instead refer the Board to the Security 4
Contentions of Suffolk County and the State of New York filed August 13,
-1984; LIIDO's Response to Board's August 14, 1984 Request for Information on the Shoreham Security Program and Reply'to Proposed Security Conten-tions, dated August 24, 1984; Suffolk County and State of thw York Reply to
- j. LIICO Security Filing, dated August 28, 1984- the transcripts fran confer-ences held August 16, 1984 (Tr. S-1 to S-94's bxrmst 30, 1984 (Tr. S-95 to S-184), and September 14, 1984 (Tr. S-IPS te 333); and the Miller aoard's September 19, 1984 Order Denying Revf W e xe. .ty Contentions (Restricted Version).
19 -
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-w In its Decision, the Miller Board characterized the contentions as follows:
A pervasive issue throughout the proferred revised security contentions was whether LIIf0's power " enhancement" equipnent should be treated as " vital," thus located in " vital areas" under NRC regulations. . . .
h e Intervenors also argued that the " change in configura-tion" wrought by the addition of the enhanc.ements created new or different vulnerabilities for the site.
Decision at 20.
. On Septenber 19, 1984, the Miller Board dmied admission of all the pro-posed security contentions, despite the fact that the Staff had agreed that cer-
- tain of the contentions were both admissible for litigation and raised legiti-mate substantive concerns with which the NRC Staff agreed. See, e.g., Tr. S-81, S-133, S-144-48, S-190-91, S-195; I4tter, dated September 11, 1984, frcan A. .
Schwencer to J.D. Isonard. his Miller Board ruling was also made in the face of LIICO's admission that the existing physical security plan had never been modified to take into account the ecnfiguration changes proposed for 1cw power operation. See e.g. , Tr. S-10, S-7C; LIICO's Response to Board's August 14, 1984 Request for Information on the Shoreham Security Program and Reply to Pro-posed Security Contentions, at 1-9.
W e Miller Board Order of September 19 was clearly erroneous. First, it appears to be premised lart3ely on the fact that, based on a re-evaluation of LIICO's proposed alternate configuration, the NRC Staff decided to support scme of Intervenors' security contentions. (bnsistent with that position, the staff requested LIICO to amend its security plan in ways alleged to be necessary in those contentions. he Staff's position was explained in a letter to LIICO which was transmitted prior to the Board's ruling on the proposed security con-tentions. A copy of the Staff's letter was provided to the Board, and prcznpted 20 -
iw -
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I i
the Board to hold a conference of counsel parportedly to discuss the Staff's position. See Order Scheduling Conference of Counsel, Septunber 11,.1984, and September 14, 1984 Transcript (Tr.S-186toS-333).l_9/
he Miller Board rejected the Staff's position on the substantive safety and security question which was raised in Interverors' contentions and supported by the Staff. In its Septanber 19 Order (at 7), the Miller Board characterized
- its action as " overruling" the Staff's position "as a matter of law" pursuant to N CFR $ 2.717(b). In its October 29 Decision, the Miller Board described its
, action as follows:
We held as a matter of law that under a request for exenp-tion frcm certain regulations for the purpose of low power testing, the power enhancements need not be treated as
" vital." 'Ib require this equignent to be treated as vital would, in effect, negate the exenption provisions. S us, we rejected contentions which asserted that the enhancements must be so treated.
Decision at 20.
Se Miller Board made its Septanber 19 ruling based on sane unexplained theory of allegedly improper NRC Staff " attempts to frustrate" the " Board's ad -
judicatory independence and integrity;" along with bizarre and undocunented suggestions of improper Staff conduct characterized by the Board as " efforts at intimidation by vituperation." See Order Denying Revised Security Contentions
. (Restricted Version), September 19, 1984, at 4-7. S e Board further l
l 19/ We urge this Board to review the transcript of the Septanber 14, 1984 con-
-ference of counsel because, in our view, it will docunent in glaring detail the Miller Board's incapability of dealing fairly with the issues. Sus,
. it will reveal a concerted attack by the Board on the Staff, pranpted so far as we can tell by the Board's outrage that the Staff had changed its substantive position on a security matter to a view which supported the County and State.
1
.n - ,,,,.,..-,,n ..,,d~,.,,.,.,.--,n-. ,,_.-.~n.,.,, .,, ,,-,-,-,,,...,._,,,n,,,,,,..,n ,.-.,-,,,n-,,,,._n,. ,-..,...--,n. , , - - -
- , -D
, characterized the Staff's statment of position in support of Intervenors'
- contentions as "an apparent attempt to influence the Board's inminent adjudica- -
tory ruling on the identical issue." Id. at 6. 'Ihere was rio basis for the Board's rejection of the Staff's position, nor for its tr,e of such rejection as the basis for its rejection of the Intervenors' conter,tions. (Again, as indi-cated in note 19, above, this Appeal Board should read the Septenber 14 tran-4 script to get a fuller tmderstanding of the Miller Board's conduct).
Second, the Board determined that it could " overrule as a matter of law" ,
the Staff's position in support of certain of the Intervenors' contentions ap-parently based on the Board's asstaption that LIICO intended its exenption re-quest to encmpass a request for an exenption frm the requirements of 10 CFR Part 73. See Decision at 7-8. 'Ihere is no basis for this asstmption; moreover,"
even if LIICO had so intended (without so indicating in its Application for Ex-emption), that does not in any way justify the Board's ruling that the Staff's i position in supporting Intervenors' contentions was wrong "as a matter of law,"
or its ruling that the contentions were not admissible for litigation in the ex-emption proceedin3 Indeed,.the Board's rulings directly contradict the July 18 Order of the Ccmmtission which recognized that security issues could arise and could be litigated in the context of LIICO's exenption application for low power i ope ration. Furthermore, even if LIICO's request had included a request for an exenption frm the security regulations, its entitlement to that exemption clearly would have been within the ambit of the exemption proceeding being conducted by the Miller Board. E/
M/ 'Ihe Board's so-called ruling "as a matter of law" also contradicts NRC precedent, Virginia Electric and Ibwer Co. (North Anna Power Station, Units
, 1 and 2), IEP-77-64, 6 NRC 008, 813 (1977), in which full implementation of i all aspects of a physical security plan was required prior to fuel loading.
22 -
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'1hird, the Board's rulings concerning the individual contentions themselves (see Restricted September 19 Order at 12-19), are clearly erroneous. 'Ihose rulings are: (a) reiterations of the erroneous and baseless so-called "conclu-sion of law" discussed above; (b) findings on the merits of the contentions, based solely upon regresentations made by LIICO's colmsel, and inyu.yer in the context of ruling on the admissibility of contentions; (c) distortions or mis-statements of the allegations contained in the contentions themselves, which are readily apparent upon reading the contentions; or (d) contrary to the well established Cmmission precedent concerning the basis and specificity require-ments for admissible contentions. See Houston Lighting and Power Co. (Allens Creek Nuclear Generating Statien, Unit 1), AIAB-590,11 NRC 542 (1980);
Philadelphia Electric 03. (Peach Bottan Atanic Power Station, Units 1 and 2),
AIAB-216, 8 AEC 13 (1974); Mississippi Power and Light Co. (Grand Gulf Nuclear
/
Station, Units 1 and 2), AIAB-130, 6 AEC 423 (1973). Ebr all these reasons, the Miller Board's Septenber 19 Order precluding the litigation of security issues identified by Intervenors and the NRC Staff arising out of LIIf0's proposed alternate power configuration and pertinent to low power operation, was clearly erroneous, in violation of the Omanission's Orders, and constituted a depriva-tion of Intervenors' right to a hearing on the security aspect of the exemption question.
- 2. Findings Relating to Security Without Any Basis in Evidentiary Record ,
Despite its refusal even to consider specifically identified security is-sues, riuch less to obtain evidence on those issues, the Miller Board nonetheless made so-called " Findings of Fact" concerning the alleged adequacy of LIIf0's
physical security arrangenents. See Decision at 76-77, 11 21-25. mreover, the Miller Board's findings 22, 23 and 24 actually track, in some respects almost verbatim, the very contentions proposed by the State and Cotmty, concerning which the Board had precluded Intervenors frm sttanitting evidence. One of
); these findings purports to rely upon extra-record LIIID and Staff representa-
[ tions made after the Board had improperly rejected the proposed contentions.
I he renainder have no stated basis Whatsoever. As could be predicted, the sub-stance of each of these Miller Board findings is as rJrm had argued: that In-i tervenors' contentions are wrong.21/
i L Given the language of Section 50.12(a) and the Otanission's July 18 order, the Miller Board knew that it had to make affirmative security findings that were favorable to LIICO in order to grant LIIIX)'s exenption request, particular-ly in view of the security vulnerabilities created by LIILO's alternate E power
! - configuration which had been recognized by the Staff (but " overruled" by the Miller Board). Se Miller Board's findings relating to security, however, are clearly without any factual basis in the evidentiary record, since the Board re- '
fused to permit any evidentiary record to be cmpiled. M us, in addition to the errors s=*vv11ed in the Board's September 19 Order denying admission of the secu-rity contentions, the Miller Board's subsequent issuance of so-called " findings" I
21/ M us, the Miller Board purported to " find" as " facts" that: " Placement of additional equipnent outside of and a reasonable distance frm the Shoreham plants vital areas, does not impair nor inpact upon established security.
procedures for protection of the vital areas"; "the need for security of emergency AC power systens during low-power is diminished"; "in the posture of a request for exenption frm certain regulations for purpose of low j~ power testing, energency AC power sources need not be protected as ' vital'
- equipnent"; and, "LIICO's security arrangenents provide reasonable assur-ance that its emergency power enhancenents will be protected during the oc-
. currence of a security-related event." Decision at 76-77.
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s e
- concerning the alleged adequacy of LIICO's security provisions constitutes an additional and even more flagrant and prejudicial violation of Intervenors' due process rights.
' C. Errors Relating to Exigent Ciretanstances FindiryT
- 1. Exclusion of Suffolk County Evidence Crsa.wiing LIICO's
, Alleged Good Faith Attempt to Otznply with GDC 17 ard Admission of LIICO Evidence on the Same Subject
'Ihe Ocurnission stated that it "regards the use of the exerption authority under 10 CFR 50.12 as extraordinary," and that such a method of relief "has pre-viously been made available by the 0:mnission only ir, the presence of excepti.on-al ciretanstances," citing thiited States Departmalt of 'Mg (Clinch River Breeder Reactor Plant), CLI-83-1, 17 NRC 1, 4-6, and the cases cited therein.
l 19 NRC at 1156, n.3. Mus, the Omanission held that "A finding of exceptional ciretanstances . . . governs the availability of an exeiption." Id. (emphasis added).- 'Ihe Ccnnission further anphasized the significance of this required finding that extraordinary conditions exist to justify granting the exceptional relief of an exenption, by expressly distinguishing the exceptional ciretznstanc-es finding fran the separate requisite findings on public health and safety and I
ccmron defense and security. M. 'Ihe Ctmnission also stated that "the.appli-cant's good-faith effort to conply with the regulation frcan which an exenption is sought" is one example of an " equity" to consider in determining whether ex-ceptional ciretznstances exist to justify the granting of a Section 50.12(a) ex-enption. Id.
LIICO asserted in its exemption application that "LIICO's strenuous efforts i' to ecmply with GDC-17 . . . weigh in favor of the exemption." Application for Exetption, at 24. LIICO also st:bnitted testinony to the Miller Doard concerning i
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LIICO's alleged good faith efforts to comply with GDC 17, and asserted that amotg LIICO's " efforts" which justify the grant of the exemption were: LIICO's efforts relating to the procurenent of TDI diesels which were designed and manufactured to meet performance standards identified by LIICO; LIICO's quality assurance efforts relating to the procurenent, design, and installation of the TDI diesels; LIICO's pre-operational testing program relating to the TDI die-sels; and, LIICO's efforts following the catastrophic failure of one of the TDI diesels at Shoreham to renedy that failure. See Tr. 1703-15.
In response, Suffolk C:y.mty subnitted pre-filed testimony on precisely the stbject addressed by LIICO. W e County's testimony established: that LIICO had failed to take reasonable actions with respect to the TDIs to ensure compliance with GEC 17; that LIICO's failures began with procurement efforts in 1974 and continued through the early 1980's; and that the failures involved, arong other things, LIICO's quality assurance efforts and pre-operational testing effort s whichwerediscussedinLIICO'stestimony.22/ For no explicable reason, the Miller Board denied the admission of the County's testimony even though it ad-mit.ted LIICO's testimony on the same subject. SeeTr.2385-89.23/ his Board 2g For the Appeal Board's convenience, copies of the County's testimony are provided herewith since, due to the Board's ruling, the testimony is not included in the hearing transcript. See Attachment 3.
M he Miller Board purported to identify grounds for its ruling striking the Cotmty's evidence, but a review of the statements by Judge Miller which constitute that ruling provides no indication that any rational basis i
3xisted for the ruling. Mus, his ruling consisted of the following obser-vations:
"he grounds upon which the Board strikes this proferred di-rect testimony is, first of all, the fact that a good deal of it goes to the issue of alleged or perceived negligence, fault or whatever." Tr. 2385.
(Footnote cont'd next page)
action es taken at T.TTm's request. See Tr. 2370-85. Clearly, there is a (Ebotnote cont'd frm previous page)
"We think, first of all, that the good faith or bad faith issues as framed by the Ommission is not an issue of con-tributory negligence." Tr. 2385.
"[T]he product of this testimony is that this direct written testinony does invade the province of the finder of fact . ... Tr. 2386.
"[W]e have no quarrel with the qualifications of these wit-nesses. We consider the to be qualified in the areas in which they have testified on voir dire . . . ." Tr. 2386. %
"[T]he expression here of those opinions is not consistent with (a) the nature of opinion testimony, and this is proferred as opinion testimony. . . . We just don't think those opinions are admissible by this panel and probably by any panel in this proceeding." Tr. 2386.
"[M]any of the instances where criticisms are made are not areas in which the Board dess it necessary to inquire. We are not holding an inquiry on the TDI matter." Tr. 2386-87.
"[W]e don't attach any significance one way or the other to the Brenner Board's inquiry . . . . Tr. 2387.
"[T]he witnesses say 'It is our position that LIICO was in effect respansible,' and so forth. Well, we don't want that kind of position frm a witness." Tr. 2387.
" Farther down in the answer [the witnesses state] 'Our point is that it is not in the public interest [. . .]' Well, I don't want a witness to have a point. I want him to testi-fy. It is only because they are experts that they can give opinions, but this is not an area for opinion testimony."
Tr. 2388.
"[W]e have indicated that good faith efforts cannot be equated with negligence or should have's in a hindsight man-ner and then suddenly sme conclusions are drawn that bingo. " Tr. 2383.
"[The witnesses state] 'Nor is it equitable to reward a utility by waiving [. . ],' now that is argmentative, it is conclusionary and again it invades a probim." (sic) Tr.
2388.
"[T] hic. is inproper opinion testimony . . . ." Tr. 2389.
denial of a fair hearing and due process when a fact finder admits one party's testimony on a subject and refuses even to consider the testimony subnitted by another party on the identical subject.21/
We prejudicial inpact of this Miller Board error is manifest in its Deci-sion. We Board found, for exanple, the following:
he testimony of [LIIf0's witness] Brian McCaffrey showed that the TDI diesels were purchased mder specifications designed to ccmply with GDC-17. When problesns were discovered, extensive ef-forts were mdertaken to cure the deficiencies.
LIICO provided a specification which called for certain perfor-mance standards and assuned through a preoperational test pro-grams that the machines were capable of running at the perfor-nance rating . . . . LIICO utilized its own and its archi-tect/ engineer's quality assurance program to oversee TDI's quali-ty assurance programs . . . .
W e preoperational test program identified problems needed cor-rection. LIICO responded by correcting individual problems and by initiating a . . . Review Program . . . .
Decision at 67.98-101. And, based on these findings, the Board concluded that "LIICO's efforts as described in detail constitute the good faith to be consid-ered in evaluating the equities, and support the grant of an exemption."
Id. at 67.
he Miller Board thus relied solely upon the LIICO testimony in purportedly
" weighing the equities" as required by the May 16 Order; in reality, of course, no such " weighing" occurred, nor could it have occurred, in the presence of only LIIf0's one-sided evidence. Moreover, despite its having stricken the County's 2g he Board also denied the County's motion to strika the LIIf0 evidence on its alleged good faith efforts concerning the TDIs in light of the Board's ruling that the County's evidence on that subject was inadmissible. See Tr. 2866-72. .
testimony concerning LIICO's efforts relating to the TDIs, the Miller Board nonetheless made ntunerous findings, based solely on LIIfD's evidence, on pre-cisely that s@ ject - LIICO's efforts relating to the TDIs. In refusing to admit the Oxnty's evidence, the Miller Board clearly denied Intervenors the right to a hearing on the subject of LIICO's good faith efforts to canply with GDC 17 and Wether such efforts constitute exigent circtanstances, one of the is-sues the Cannission had expressly identified as pertinent to an exemption ruling.
- 2. Improper Reliance Upon Evidence (bncerning the Iangth and Costs to LIICO of the Shoreham Licensing Proceeding LIICO's evidence concerning the alleged existence of exigent circumstances to justify an exenption also included testimony concerning the length and costs of the NRC licensing proceeding. Intervenors moved to strike as irrelevant this testimony (Tr. 1715-31), in which LIICO (a) conplains that the Shoreham proceed-ing has lasted for several years, (b) alleges that the Staff has imposed extra and technically unjustified burdens on LIICO, and (c) conplains that LIICO has had to expend a great deal of resources in pursuing its quest for a license.
See Tr. 1600-92. 'Ihe Staff agreed that this testimony was irrelevant and supported the motion to strike. Tr. 1693. Once again granting LIIf0's request I
(Tr. 1693-97), the Miller Board overruled the Intervenors' and Staff's motion and admitted the testimony sutmitted by LIICO. Tr. 1698.
l
'Ihere is no indication in any Ocnnission precedent that such evidence (even i
if believed) would support the extraordinary relief of an exernption. 'Ihis LIILO
, testimony amotmts to nothing but an assertion of LIIf0's apparent belief that it has a right to receive a license fran the NRC. In fact, Mwever, it is clear 4 that nobody has a right to an NRC license; all persons applying for such
- e. _.
licenses do so at their own risk and subject themselves to the NRC's rules and regulations, to the rulings of Licensing Boards and the (kmuission, and to the technical judgments and requirenents of the NRC Staff. here is simply no basis for LIICO to corplain about the NRC licensing process, actions of the NRC Staff,-
or the length of the IrWing. Bere is certainly no basis for LIICO's auda-cious non sequittr that because it has been involved in a contested NRC licens-ing Iroceeding convened to test LIICO's coupliance with NRC cafety requirmts,
" fairness requires" it shoulinow be granted an exenption fran ocinplying with those very NRC safety requirenents.
Nonetheless, the Miller Board relied heavily upon this LIICO testirnony in its Decision:
Se costs of tmusually heavy and protracted litigation may also properly be considered in evaluating financial or eco-ncaic hardship as an equity in this exenption proceed-ing . . . . It is beside the point to argue that such liti-gation is permitted under NRC regulations. Although not 11-legal, such interminable litigation has resulted in great expense to LIICO, both in terms of time and resources. . . .
S e unusually heavy financial and w uTde hardships associated with the very protracted Shoreham licensing pro-
, ceedings constitute a significant equity, which we hold can reasonably be held to amount to exceptional ciretanstances in the context of granting a low power exenption.
Decision at 62-63 (arphasis added). See also id. at 59-60. % ere is no legal, factual, or logical basis for the Board's conclusion that LIICO's litigation costs constitute exigent ciretastances Wilch justify an exenption fron conpli-ance with important safety regulations.25/ . We Board's reliance upon LIICO's 2_5/
5 me Staff and the Consnission's Licensing Boards are required to make spe-cific findings concerning the safety of a nuclear plant, and they undertake whatever reviews are necessary to enable them to make the requisite find-ings. We fact tht for Shoreham extensive Staff review and hearings on contentions admitted by Licensing Boards have been necessary to enable the (Footnote cont'd next page)
A
- o e clearly irrelevant testimony, as well as its cor. sideration only of the alleged financial and econmic hardships borne by LIICO and its refusal even to consider those put forth by the State and the Cbunty which would be borne by the public (see Section II.A above), constitute clear error, and one more instance of the Board's denial of a fair trial to Intervenors.
- 3. Inproper Consideration of Prior Staff Practices as Basis for Finding Exigent Ciretznstances to Support Exenption In purportedly " weighing the equities" and determining that exigent cire m-stances exist, the Miller Board considered alleged prior Staff practices in per-mitting the issuance of licenses despite norm.u yliance with safety regulations.
See Decision at 63-66. 'Ihe information apparently relied upon by the Miller Board concerning such prior Staff practices is not in the evidentiary record and
- . was never available to be cross-examined. Clearly, the Intervenors had no op-porttnity to challerge the relevance, similarity or applicability to the facts at issue in this proceeding of the information apparently relied upon by the i Miller Board. 'Ihe Miller Board's reliance upon such extra-record infontation is clearly erroneous, and constitutes another example of its abuse of due process in an effort to provide a license for LIICO.
Further, the Miller Board's suggestion that the Staff's behavior in situa-tions involving other utilities or regulations smehow justifies the issuance of 1
a license in the face of LIICO's non-cx:mpliance which is at issue in this (Ebotnote cont'd frcm previous page) l t Staff and Boards to make the findings required under the regulations, does not constitute the kind of ~" exigent circumstances" which justify the grant of an exenption or the issuance of a license.
l l
l l
L .- . . - - _ . - . . - . , - . - - - _ . - - . - , - - . . - _ - , _ , - , - - . . . - , - _ - . - _ . - - . .
o .
proceeding, whether on the basis of a " constitutional equal protection" theory,2,6/ or for the sake of " consistency," is patently absurd. 'Ihe Ocmnission has ruled expressly on how LIICO's noncanpliance with the Ocmnission's regula-tions must be handled. See 19 NRC at 1155-56. Whatever the Staff may have done prior, or_ even subsequent, to the Ocmnission's Shoreham rulings with respect to other plants, and whether such actions were right or wrong, cannot change the Ccanission's ruling that LIIf0 must meet the Section 50.12 standards as enunci-ated in the May 16 Order. 'Ihe Board's finding that allegedly " inconsistent" Staff practices constitute an exigent circumstance that justifies granting the exeroptica request is without any legal or factual basis and is clearly errone-ous.
D. Errors Relating to the As Safe As Determination
- 1. Exclusion of Suffolk Cbunty Testimony Milch Demonstrated that Operation With the Alternate AC Power Configuration Would Not Be As Safe As Operation With a Ebily Qualified' Cn-Site Power Systern, and Admission of All Evidence Subnitted by the Staff and LIIf0 Concerning the "As Safe As" (bnparison In,its May 16 Order, the Ocnnission established that to obtain an exemp-tion, LIICO must denonstrate "that, at the power levels for which it seeks au-thorization to operate, operation would be as safe under the conditions proposed by it, as operation muld have been under a fully qualified on-site AC power l source." 19 NRC at 1156.
F LIIf0, the Staff, and Suffolk County subnitted testimony concerning: (1) the reliability and operational capabilities of the individual items of l
2g See ASIB Order Reconsidering Suntnary Disposition of Phase I and Phase II Iow-Power Testing, Septenber 5,1984, at 7, referenced in Decision at 64, n.133.
l l
l l .
i
..-. - - . - _ _ - - - - - - _ = - - _ _ . - - - - _ -. _ , , - - - . - - . - - - - - - - - . - - . . . - - . . .
e .
s equipnent Wilch make up LIICO's proposed alternate power configuration (i.e.,
the EMD diesels and the gas turbine); and (2) whether low power operation with the alternate M power configuration as a whole, would be as safe as operation with a fully qualified onsite M power system.2_7/ 'Ihe Board admitted substan-tially all the attmitted testimony on the first subject, including that sub-mitted by Suffolk Cotmty. 'Ihe Board also admitted LIICO and Staff testimony which asserted that operation of Shoreham with the alternate M power configu-ration as a whole would be as safe as operation with a fully qualified on-site AC power syst s. At LIICO's urging, however, the Board refused to consider the
- Suffolk Cotuty testimony which ccmpared the safety of low power operation with the alternate M power configuration as a whole, with that of such operation with a qualified e .-site configuration. See Tr. 2844, 2856-58. In making this ruling, the Miller Board once again followed its pattern of denying Intervenors a fair hearing on one of the issues central to the exenption prWing.
It is not surprising that LIICO and the Miller Board did not want the Coun-ty's testimony in the evidentiary record: the County testimony demonstrated that operation of Shoreham with the alternate M power configuration would not be as safe as operation with a fully qualified onsite power system.28/ rige County witnesses had perfonned both qualitative and quantitative (PRA) analyses i
in support of their opinions. 'Iheir testimony documents that low power operation with the alternate AC power systen is quantifiably less safe than low I
2_7/ See Tr.198-228, 265-323, 400-524, 554-78, 845-68, %2-1021, 1160-1211 (LIICO); Tr. 1782-1800, 1849-53, 2337-57 (Staff); Tr. 2572-635, 2762-819, l 2842-44 (submitted, but denied admission) (Suffolk County).
2_8/ Copies of the County testimony, which due to the Board's ruling is not contained in the hearing transcript, are provided herewith as Attachment 4.
l' i
1 _ _ _ _ ~ . - . . - . . . _ . _ _ _ , _ _ _ _ _ _ _ _ _ _ . . . _ __..._._ _ _ _. __ _ .__ __
1 o- e I power operation with a fully qualified AC power system: a loss of off-site power transient during low power operation of Shoreham is seven times trore like-ly to lead to a core vulnerable condition with the alternate configuration than l 1
with a fully qualified source of on-site AC power; and the likelihood that Shoreham would experience an event leading to core vulnerability during low power operation is two and one-half times greater under the alternate configura-tion than it would be tmder a qualified configuration. See Attachnent 4. Such 9
testimony was directly responsive to the cmparison mandated by the Ocnnission's May 16 Order.
Se Miller Board clearly erred in refusing to admit this testimony.29/ ge 2_9] he Board's assertion that a probabilistic risk assessment is not "a proper method to be used in this proceeding" (Tr. 2858) as a basis for its ruling is simply wrong and, in any event, is beside the point. PRAs have been required by the Staff in sme proceedings (see, e.g., Tr. 2857), and the
- full power PRA performed by LIICO has been reviewed by the Staff and was considered by the Brenner Board and, indeed, by this Board in AIAB-788.
See Iong Island Lighting (b. (Shoreham Nuclear Ibwer Station, Unit 1),
AIAB-788, NRC (1984) (Slip op. at 42-48). ntrthermore, while there may be no requirement to perform PRA analyses as a general matter, there is also no bar to the use of probabalistic data, if available, to evaluate the relative safety of operation in differen'. configurations. See, e.g. , Let-ter dated June 15, 1984 frm Nunzio J. Palladino to the Honorable FAward J.
Markey and attachnents thereto. We renainder of the Board's observations which ccmprise its " ruling" also state no rational basis for its refusal to admit the County's evidence:
"[me testimony] is not relevant to the issues raised by this 1cw power licensing proceeding."
"We do not believe that it would aid the Board in decision-making. We believe that there is sufficient deterministic evidence frm which determinations can be made for an examination of the record, and we believe that that is the present situation, both insofar as the Comnission's rules are concerned, and in the way in which such rules, particularly those relating to probalnlistic risk assess-ments should be determined in this case."
"We have no desire under those circumstances to go into (Footnote cont'd next page)
e e prejudice to Intervenors which resulted frm the Board's ruling is again mani-fest in its Decision. Although the Board discussed to a limited extent the reliability of individual items of equipnent involved in the alternate AC power configuration, as to which the Cotmty's evidence was admitted, it also asserted that a " point-by-point emparison of Shoreham's emergency power configuration with TDI diesels and without the" is not a proper emparison; rather, the Board asserted, a "ftmetional cmparison," which was urged by LIICO, is proper. See Decision at 22, 25-26. By its "ftmetional emparison" the Miller Board appar-ently meant a system emparison rather than a cmponent emparison. Id,. In discussing its "ftmetional cmparison," however, the Board considered only the LIICO and Staff testimony, since the County's evidence which cmpared the safety of the ftmetioning of the two systems during low power operation was denied ad-missionbytheBoard.3,g/
(Footnote cont'd frm Irevious page)
[the substance of the testimony] can in any way have a rele-vance to this proceeding." (sic)
Tr. 2858 (Miller).
30/ 'Ihe Board inproperly characterized the County's position in the hearing as being limited to "a point-by-point emparison of cmponents of systems."
Decision at 22-23, 25. 'Ihe Board similarly incorrectly asserted that:
Suffolk (bunty's testimony was devoted almost exclusively to shewing that each tmit in the enhanced system (the gas tur-bine and the DfDs) ws either inferior to the qualified sys-tem or, iiv the case of the EMDs, that the potential existed for a single failure Wich would disable all four of them.
Id,. at 50-51. Such charucterizations of the County's testimony are in fact largely a reflection of the Board's own erroneous rulings. See also dis-cussion in Section II.D.2 below.
4
o o Despite its refusal to consider the Cotnty's testimony, the Miller Board found that operation with the alternate AC power configuration "provides a ecmparable level of protection as a fully-qualified systen would and thus meets the 'as safe as' standard set by the Ocnnission in CLI-84-8." Id. at 55 (stpha-sis added). See also id. at 102. Clearly, in reaching its "as safe as" - or "conparability" - conclusion without even considering the County evidence con-cerning the precise ecmparison mandated by the Ommission, the Board erred, and denied Intervenors a hearing on an issue central to the exertption request. In-deed, in ignoring evidence that low power operation under the exemption would be seven times less safe than with a qualified AC power systen, the Miller Board made a mockery of the entire proceeding.
- 2. Imwr Application of Ocmmission's As Safe As Star {ard The Ocnnission's requirenent that low power operation "be as safe under the conditions proposed by [LIICO2, as operation would have been under a fully qual-ified on-site AC power source" (19 NRC at 1156) was mandatory and binding upon the Miller Board. In its Decision, the Board appears to adopt the view tMt the Ccmnission's "as safe as" standard means "a comparable level of protection."
See Decision at 27.
'Ihe Board's interpretation and application of the Crzrmission's' standard, as manifested in the Decision, was clearly erroneous. 'ihe Omnission's standard calls for a direct conparison of the two AC power configurations - the alternate systen versus the fully qualified system. If the safety provided by operation with the alternate systera does not fully measure up to that provided by operation with a fully qualified system, then under the Ocmnission's standard the exenption rrust be denied.
9 O-Se Q:ssnission's requirement that the safety of operation under each con-
- _ figuration be the same, is a reasonable one. m reover, it is particularly cr t-ical' in the context of low power operation, Which is at issue here, 'since the Ccmenission's regulations (10 CFR I 50.47(d)) pennitting low power operation without an approved off-site emergency plan are premised on there being a margin of safety during low power operation that is greater than that present during full power operation. See 47 Fed. Reg. 30,234 (July 13, 1982). Clearly, any reduction in safety margins during low power operation due to the use of the alternate AC power configuration wuld tmdercut empletely the rationale tmderlying 10 CPR {50.47(d), and thus render it illegal for the NRC to authorize a low power license without a fully approved and inplananted offsite emergerx:y plan. Accordingly, the Omnission's clear requirement that for an exernption to be granted fbr icw power operation there must be no erosion in the margin of safety that would be provided by a system in full ocupliance with the regula-tions during low power operation, makes sense and indeed rest be applied strict-ly. Se Miller Board refused to apply that requirement in ruling on MIco's ex-enption request.
For exanple, in its Decision, the Miller Board recognized, but then ignored by ruling in MIco's favor, the obvious reduction in safety that would result fran low power operation with the proposed alternate configuration. %us, the Miller Board admitted that "there is tmquestionably a lesser margin of safety provided by MIro's alternate power system" (Decision at 24, enphasis added),
thereby establishing that MIco does not satisfy the Omunission's straightfor-werd "as safe as" standard. Similarly, the Board found that "It is, of course, obvious that a fully qualified system muld have an established and documental L .
r-e e higher resistance to seismic events than does the su em proposed by LIICO . . ., " (id_., at 52), again establishing that operation with LIICO's alternate configuration inherently provides a lesser margin of safety. Ebr this Board to affirm the Miller Board's recarenendation of a low power license given these factual findings would be to violate the May 16 order and 10 CFR
$ 50.47(d) as well.
ha Miller Board also rejected as irrelevant the fact that a qualified sys-ten could provide emergency power to safety loads within 15 seconds, whereas the alternate configuration could not supply power for a minimtsn of several, but up to 30, minutes. he Board thus found that since there are at least 55 minutes to restore power before core damage results during low power operation, it is not significant that tmder LIICO's alternate configuration 30 minutes of that time (as opposed to 1F seconds) could be necessary before any power is available
. - or before it is even known by plant personnel that power will not be avail-able. See id. at 23-25. Such a finding is plainly inconsistent with the Ccm-mission's "as safe as" standard.
We Miller Board's finding that evidence concetning the inferiority of the alternate equipnent proposed to be used by LIICO, and its vulnerability to cin-glo failures we " irrelevant" (id. at 51) is inexplicable, and clearly errone-ous. What could be more relevant to findings under the' "as safe as" criterion than a discussion of the vulnerabilities and inferioritius of such equipnent as compared to those in a fully qualified systen? Similarly, the Doard's assertion that "there is no need to consider the relative merits of the two systems I=r, se_, because for the purpose of the exenption request, it is only necessary to establish that the enhanced systern is capable of perfonning its intendai,
e o function" (id. at 52 (anphasis added)), is yet another example of the Board's inproper application of the standard set by the Omnission. 'Ihe capability of performing a particular function is clearly important; however, the finding man-dated by the Ckmmission must go beyond mere abstract capabilities to determine whether in light of the alternate system's capabilities, actual plant operation would be as safe as operation would be given the capabilities of a qualified system.
Clearly, the Miller Board ignore 1 the standard set by the Ctmmission: the Ccanission did not set a standard of Whether operation with the alternate con-figuration would, in the judgment of the Board, be safe enough, nor did the on-mission instruct the Miller Board to ecue up with a definition of how much safe-ty is "enough." Rather, the Ommission, certainly mindful of the impact of the exemption request on other NRC regulations (such as 10 CFR $ 50.47(d) discussed above), instructed the Miller Board to determine Wether operation with the alternate configuration would be as safe as operation wxild have been with fully qualified TD1 diesels. A reduction in the margin of safety, or a reduction in the defense in depth protection which is central to the NRC's licensing concept, cannot be ignored tmder the Omnission's as safe as standard. Plainly, however, the Miller Board did exactly that.
Apparently as a result of its distortion and misapplication of the "as safe as" standard, the Miller Board failed to consider, or sinply chose to ignore, facts set forth in Suffolk County's expert testimony, Which doctanent a real re-duction in safety that would result frcm operation with the alternate configura-tion as ccinpared to that with a qualified configuration. All these facts, with citations to the record, are set forth in the County and State Findings stimtitted to the Miller Doard. Sczne example are set forth below.21./
31/ We note, Were appropriate, that the Decision did at least acknowledge that same of the facts were presented by the County; however, the Miller Board a
(Footnote cont'd next page)
e' o .
- 1. - '!he alternate configuration contains only two power sources, Whereas the qualified configuration contains three power sources. Clearly, there is less rodadancy and thus, a reduced nargin of safety, with the alternate config .
uration.
- 2. Dortions of the tw alternate configuration share cannon elements with the off-site power systeun and also share common features with each other, chus making the alternate systein s@ ject to single failures. In con *rast, each of the three qualified diesels is a coupletely independent power source that is physically isolated fran endh of the other two and is fully independent of off-site power sources. See comty and State Findings 107, 108, 285-91 and ci-tations therein. Clearly, the alternate syntain's vulnerability to single fail-ures, and its vulnerability to a cannon mode failure of the offsite systeen, rep-resents a s@stantially reduced margin of safety as campared to a qualified sys-
. tasa.
- 3. One-half of LIIco's alternate configuration - the set of fbur EMD die-sels - is s4 ject to single failures that would disable the entire set of die-sels, because the fbur units share a common fuel system, a oceenon starting sys-tem, cannon output cables and cannon controls. In contrast, eedh of the three qualified diesels meets the single failure criterion. See com ty and State Findings 104, 105, 108-130 and citations thereint Decision at 88, f 68. Again, t
the vulnerability of one-half the alternate system to disabling single failures l (Footnote cont'd fran grevious pege)
- inexplicably concluded that operation with the alternate configuration would be as safe as operation with a qualified system in the face of the i
clear evidence to the contrary *ich we suonarize in the text.
b i -e-e--------_--._.-
e e nakes the margin of safety and defense in depth protection substantially less than that available with three single failure-proof p e r sources.
- 4. Operation of the alternate configuration requires many manual i
operations, in several different locations both inside and outside plant build-ings, giving rise to anny opportunities fbr human error. In contrast, a quali-fled syste is fully autmatic. See Cotmty ard State Findings 164-65, 167-78, 267-78, 263-64, and citations thereint Decision at 88, 11 66 and 89, 1 73.
Clearly, the reliance upon human operators to perfom both properly and rapidly in the event of a station blackout, reduces the margin of safety fra that available with a fully autmatic emergency power systen. ;
- 5. 'Ihe alternate configuration is vulnerable to seimnic events and is likely to fail in an SSE; a fully qualifiel system is designed to withstand the SSE. See Cotmty and State Findings 15-71, 77-80, and citations therein. 'See also Decision at 52 ("It is, of course, obvious that a fully qualified system would have an established and doctanented higher resistance to selenic events l than does the system proposed by LIlco . . . ."). clearly, a reduced resistance to seisnic events and a likelihood of failure in an SSE, means that there is a smaller margin of safety of operation with the alternate configuration.
- 6. 'the alternate configuration has essentially no local fire detection or extinguishing systems, and there is a potential for fire and explosion because of the IMDe' battery starting systen. and poor ventilation. In addition, the at>-
normal condition alarms associated with the alternate configuration are not annunciated in the control rom. In contrast, a qualified syntan includes both l fixed fire detection and extingulshing systems for each generator, no battery l
l systen, and a emprehensive alam system ditch is antnnciated in the control l
t
r e roon. See Cotmty and State Findings 131-63, 260-62 and citations therein; see Decision at 88, 1 69. Clearly, there is a substantial reduction in safety mar-gins, as empared to those present with a fully qualified system, if necessary equipnent, such as that in the alternate configuration, is vulnerable to fire Wilch may not be detected or extinguished, and if information concerning the ab-normal status of necessary equipnent is not innediately available to the plant operators.32/
- 3. Incroper consideration of offsite Power systen In its Decision, the Miller Board discusses. what it terms the " reliability of LIID0's normal off-site power syntam." Decision at 40-46, 82-85. After describirg various aspects of LIIro's off-site AC power system, the Board con-cludes that it is "tmlikely that power wuld be unavailable to either the NSST or the RSST fran normal off-site _ sources." Id,. at 46 (atphasis added).
. However, this exatption proceeding exists because LIICO does not have an on-site electric power systen. The Miller Board as instructed by the Ominis-sion to consider whether LIIf0's alternate configuration - offeral as a substi-tuted fkr a qualified onsite system - would result in low power operation that wuld be as safe as that available with a fully qualified on-site power systen.
Thus, LIICO's offsite power system is simply irrelevant to the required safety finding. Clearly, the focus of this proceeding us not meant to be LIIro's normal offsite power systan: that is a constant Which appears on both sides of 32/ narther, at least 16 additional technical specification requirenents and 9 license conditions must be imposed before operation with the alternate con-figuration wuld be acceptable to the Staffr none of these rmIuiranents or conditions muld be needed with a qualifisi source of AC power. See County and State Finding 297, tuv1 citations therein.
0 0 the emparison mandated by the Cbmission. Rather, the focus us to be the reliability and capability of LIICO's proposed alternate configuration (the gas turbine and des) as empared to a fully qualified on-site systen. Rus, to ecmpare the relative ssfety of operation with a qualified on-site system and with LIICO's proposed alternate configuration, it must be asstaned that the off-site systen is not functioning. GDC 17 itself mandates the asstaption that the onsite system will fmetion asstming the offsite system is not functioning. ,
he Miller Board's speculation about the adequacy of LIICO's off-sito system and Miether a loss of off-site power muld be likely us irrelevant. Its reliance upon such speculation in making its "as safe as" finding ws a clearly erroneous misapplication of the law and the Cbmission's rulings.
E. We September 5 Phase I and II Miller Board Order Violates the Ctamission's Rulings and Regulations _.
In its September 5,1984 Order Reconsidering Stenary Disposition of Phase I and base II Iow-Power Testing (hereinafter, " September 5 Order"), the Miller Board ruled that LIICO could load fuel and perfonn certain low powr testing prior to a decision on its pending exenption application.$ hat ruling vio-lated the Ccamission's May 16 Order, and us clearly erroneous as a matter of law.34/
33/ See Decision at 5 for the Miller Board's definition of mases I and II.
34/ Althotr;h the Otzmission stated that it had perfomat an inna11 ate effec-tiveness review and, stbject to certain conditions, ruled that the Miller Board's September 5 Order could becme effective (see Memorandtsn and order dated November 21,1984 (CLI-84-21)), purstant to T5 CFR $ 2.764(g), this Appeal Board is prohibited fran attaching any wight to either the Ctmmis-sion's effectiveness datomination or any ccanents containel in the Ctmmis-clon's Novernber 21 Order.
- a LIICO first requested the sumary issuance of a license for Phase I and Phase II activities by its filing of Sunenary Disposition Mtions directly with the Omanission on thy 4,1984.35/ During the May 7 oral argtanent before the Ccaunission Wtich preceded the my 16 Order, LIICO's cotrisel discussed Phases I and II at considerable length in arguing that no exemption frun GDC 17 was required prior to the issuance of a low power license to perform Phase I and Phase II activities. For exargle, the following statements were made to the Ccmenission by LIIco's counsel:
We meet (GDC 173 in light of its application to a low power license. We do not have an cruite power system strictly speaking. However, in order to apply GDC-17 at this level of operation, you have to take into consideration the meaning of 50.57(c). And Wsat LIICO says is that in in-terpreting the regulation for low power licensing, one ought to lock at the level of operation intended and interpret the regulation, the General Design Criterion, ,
accordingly . . . . (b ife, Tr. 15).
. [F]or Phases 1 and 2 there is no risk to public health and safety because there is no need for AC power . . . .
And for tMee reasons, LIIro asks that the Ccmsnission rule new and grant its motions for sumary disposition for Phases 1 and 2. (Rolfe, Tr. 24).
However, the Omsnission rejected LIIf0's express argtanents that no exemp-tion fran GDC 17 was necessary for Phases I or II of its icw power proposal. It stated:
After reviewing the oral argtments and written subnissions of the parties, the Censnission has determined that 10 C.F.R. 50.57(c) should not be read to make General Design criteria inapplicable to low-power operation.
19 NRC at 1155. 'Ihe Ccmunission stated further 35/ g LIIro's mtion for Stanmary Disposition on Phase I Iow Pcwer Testing dated My 4,1984, and mtion for Sumary Disposition on Phase II Iow Power Testing, dated May 4, 1984.
44
o a .
[T]he applicant made clear at the May 7 oral argtsnent its intent to seek an exatption under 10 C.F.R. 50.12(a). If it intends to follow that course, the applicant should' modify its application to address the determinations to be made tmder 10 C.F.R. 50.12(a).
Id.
d at 2 (emphasis added).36/ Mus, the Otanission's rulings that GDC 17 is ap-plicable to LIIro's low power proposal and that LIICO must address in a modified application fbr a h w power license the determinations Which must be made in-granting an exenption fran regulatory requirenents under 10 C.F.R. { 50.12, are applicable to Phase 1 and Phase II of LIIro's pre-a1.
Furthermore, if the Otanission had intendet to limit its ruling on the re-quiranent fbr an exasption to only portions of LIICO's icw power license appli-cation, it certainly would have said so. Indeed, LIIro had expressly requested the Ocnnission to rule that it could obtain a license for Phase I and II activities without havirg first obtained an exenption. Nwever, the Ctanission refused to grant LIIro's stannry disposition motions, and it did ret in any way limit or restrict the applicability of its my 16 ruling on LIIro's need for an exemption in order to obtain its requested icw power license. Wat is the unmistakable law of this case, which simply cannot be ignored.
Despite its failure to persuade the Ocnnission that without having met the standards for an exenption and in the absence of an onsite AC power systen, LIICO nonetheless made the identical arguments as to Mty it should receive a 11-cense in its my 22 Stenary Disposition mtions filed with the Miller Board.
3g he " application" referenced by the Ctmnission necessarily meant the itens submitted by LIICO for the Ccmnission's consideration - that is, LIICO's Supp)emental mtion for Iow Ibwer Operating License (Which included Phases I and II), and LIIro's Sunnary Disposition Ntions on Ihases I and II.
r
! l
_ _ _ . _ - . _ . . , _ _ _ - - _ _ _ _ _ _ . _ . ~ _ . _ _ , _ _ , _ _ _ . _ _ _ . _ _ . _ _ _ _ . _ _ .
- =
'Ihus, in those motions, LIICO argued that obtaining an exenption frcm GDC 17 was not a prerequisite to the issuance of LIICO's self-styled licenses for Phases I ard II. LIICO asserted that stenary disposition was proper on Phases I and II because "the reliability of LIICO's onsite diesel generators is not material" to either of those phases since, according to LIICO, "there is no need for any AC power" during those phases. LIIf0 used this logic to conclude that the require-ments of GDC 17 wuld be met during Phases I and II, even assuning LIIf0's onsite diesel generators do not operate. See Phase I Motion dated May 22, at 4, 5; Phase II Motion dated May 22, at 3, 6.
However, even LIICO ma forced to recognize that its argunent flew in the face of the Comnission's May 16 Order. 'Ihus, LIICO stated in ito Phase I Sama-ry Disposition E tion filed with the Miller Board (at 5, n.1):
If the Licensing Boe believes the Cannission's May 16 Order requires an exemp from the regulations for all
. four phases of low power te n the Board should treat this motion as a motion for stmnary disposition of all health and safety issues with respect to Phase I.
An identical statement, with " Phase II" substituted for " Phase I" is in footnote 2 of the May 22 Phase II Motion filed with the Miller Board.
On July 24, 1984 the Miller Board held that an exenption was required be-fore a Ehase I or Phase II license could be issued. In so ruling, the Miller Board accepted the positions of the NRC Staff, the State of New York, and Suffolk (bunty, that the Ocmnission's May 16 Order prohibited the issuance of
, the licenses requested by LIICO, prior to ccupletion of the exemption proceed-ing.3]/
37/ Suffolk County, the State of New York, and the Staff had all urgel the Li-censing Board to apply the my 16 Order and to hold that an exenption was (Footnote cont'd next page)
-i t -o
'Ihus, in its July 24 Order Granting in Part and Denying in Part LIICO's rio-tions for Simnary Disposition on Phase I and Phase II Iow-Power Testing, the Miller Board held:
'Ihe Omnission's May 16 Order (CLI-84-8) stated that it "has dete-ined that 10 CFR 50.57(c) should not be read to make General Design Criterion 17 inapplicable to low-power operation" (slip opinion; page 1). 'Ihat order therefore stands for the proposition that GDC-17 means the same for low-power operations as for full-power. operation, and it -
must be ccupletely satisfied before any license (including
. low-power) may be issued. Accordingly, the only recourse available to mm in this IrWing is to seek an exemp-tion tmder the provisions of 10 CFR $ 50.12(a), which is the stbject of the instant evidentiary hearing.
'Ihe Board does not have the power or jurisdiction to grant LIICD's motion for suonary disposition of Phases I and II of its low-power testing Irogram, even though such activities
.do not require a qualified source of onsite AC power in order to perform the _ safety ftmetions specified by GDC-17.
'Ihe Otanission's order requires that the GDC-17 requirements '
be empletely satisfied even for fuel loading and precriticality testing. In its motion LIICO did not seek simnary disposition of its exmption request, nor did it even address.the factual issues involved therein. Accord-ingly, the ultimate issues involved in Phase I and II activ-ities cannot be disposed of stnmarily, and that portion of the stenary disposition motion ~is denied.
July 24, 1984 Order at 9-10 (enphasis added).
'Ihen, without having a motion for reconsideration before it, and in the ab-ll sence of any material changes in circunstances, facts, or the law, the Miller.
i Board sua sponte issued its September 5,1984 Order in tahich it reversed itself I
(Footnote cont'd frcza Irevious page) >
, required for Phases I and II. See NRC Staff Response to LIICO Motions for Stenary Disposition of Phases I and II, June 13, 1984; Suffolk Cotmty and State of New York Memorandum in Opposit. ion to LIICO's May 22, 1984 Motions i
for SLmnary Disposition on Phase I and Phase II of LIICO's Proposed "Iow
[ Power Testing," June 13, 1984 (hereinafter, " June 13 filing").
1 i
. - - + . ,,e.., ~---_,--~,-,-~__.,m.._~mw...,me-,,v.,,-.wm.mm...rw--,,_.-,,,,,,-_m-r---ww._.m--,,
t . . ;
(and apparently discovered " power" and " jurisdiction" where none previously existed). 'Ihus, in a conplete reversal, the Miller Board held in the Septaber 5 Order that LIICO need not demonstrate the bases for a Section 50.12(a) exemp-tion prior to issuance of a Phase I and Phase II license.
, However, the Board had no reason for changing its mind on September 5.
Indeed, nothing material had changed since July 24. Ebr the Miller Board to have changed its July 24 decision in the face of no new material- facts merely underscores the capricious and tmsuported nature of its action.
'I%o purported " bases" for the Miller Board's abrupt reversal of position were set forth in the September 5 Order. Neither bear up under scrutiny.
First, the Miller Board once again sought to get arotmd an instance where the Staff b supported the Intervenors in a position contrary to LIICO's interests by its having opposed the LTToo stamary disposition motions. In the September 5 Order, the Miller Board attempted to create the appearance of Staff support for LIICO's Phase I and II license request, and then bootstrapped that wholly illu-sory Staff " support" conjured up by the Board, into support for the Board's own, independent, desire to grant LIILO's request. '1hus, the Board seized upon the Staff's August 17-Response to LIICO's Motion for Directed Certification of the Licensing. Board's July 24 Order, in which the Staff reiterated its view that under the Ocnnission's May 16 Order an exemption was required for Bases I and II (see Staff Response at 3-4), and because the Staff also stated that "Ccanis-sion guidance would be helpful," the Board stated "the Staff rather abruptly and without adequate explanation again changed its position." Septaber 5 Order at 4 (enphasis added). Clearly, the Staff's position concerning the need to deny LIICO's Phase I and II license request renained unchanged; its belief that
P
- Ccmnission guidance would be helpful could well have reflected a belief that the Miller Board was incapable of properly conducting the exenption proceeding on its own - a. belief shared by Suffolk County, New York, and two of the Ocmnis-sioners.38/
Furthermore, although the Miller Board purported to find support for its own changed position in the Ocmnission's meeting held on July 25, 1984 and Staff statenents discussed during that meeting (see September 5 Order at 4-6), the ac-tual outcone of that meeting was that the May 16 Order would continue to apply to Shoreham. Se Q:mnission itself confirmed that outcone in a vote recorded in Mr. Chilk's July 27 Memorandun to the General Counsel and EDO. h us, despite the defensive rhetoric in the September 5 Order, in fact the Miller Board had no legal or factual basis diatever for its abrupt, and clearly inwr reversal.
Second, the Board also purported to base its September 5 Order on its con-cerra that a court of law reviewing these orders might well con-clude that LIICO was being discriminated against and treated differently than other utilities similarly situated, con-trary to the equal protection of the laws and the due prc>-
cess requirenents of the Fifth Amendment to the Uhited States Constitution.
Septenber 5 Order at 7. h is is a baseless statement which this Appeal Board should discard sumarily. Indeed, a court "might well" do one thing or another.
I It is no more than playing with a crystal ball for the Board to engage in su::h I wholesale speculation. he fact is that the issue with which the Miller Board l
was apparently so concerned "might well" never even get to court. What is most i
38/ See my 16 order, Separate Views of Ccmnissioner Gilinsky and Additional Views of Omnissioner Asselstine,19 NRC at 1159-60.
i
P o important here is not what "might well" be done by scmeone else sme day, but what should have been done by the Miller Board (apply the Conmission's May 16 Order), and what now must be done by this Appeal Board under the ru1.e of law and the facts of record.
Further, as this Brief makes clear, the Board's invocation of the spectre of due process and equal protection of the laws with respect to its treatment of
, LIICO in the exemption proceeding is totally unfounded and clearly misplaced.
We Miller Board's solicitous attention and concern for protecting LIICO's rights is particularly irdefensible in light of its consistent actions to deny the Intervenors' due process rights. We Board's " constitutional" concerns for LIICO's welfare are nothing but abstract rhetoric, wholly lacking any reference to the particular facts of record in this proceeding, and the Board cited no legal auth6rity whatever to support its conclusory statenent. For these and the reasons stated in Section II.C.3 above, the Pdller Board's constitutional theory must be rejected.
!breover, the issue presented by the Miller Board's September 5 Order has nothing to do with that Board's alleged concern for "similar.7// situated" utilities - Grand G21f, Catawba, or any other.3,9/ W e issue has only to do 39/ In fact, contrary to the unsupported assertions of the Miller Board, these other utilities are not "similarly situated." If the Board had asked for the parties' views prior to its sua sponte Septensaer 5 Order, the County and State muld have so informed the Board. Ebr example, Shoreham's TDI diesels are straight, 8 cylinder diesels; those at Catawba and Grand Gulf are V-8 or V-16's. Eus, the diesels at Shoreham are different in impor-tant respects. Second, the crankshafts at Shoreham are totally different frcm those at Catawba and Grand Gulf. hird, at Shoreham the crankshafts have cracked, the replacenent crankshafts have been found by the Staff not to meet the DEMA standards set forth in Reg. Guide 1.9, and the engine blocks have had extensive cracking. None of these probleus has occurred at Catawba or Grand Gulf.
-y - -n-,, , - -- .- , -- n--a ,,. - ne , - - - - n , ---,-. , ,- , _ - - , - .,--
e ..
with the Miller Board's clear failure to apply the Ocunission's May 16 Order to Shoreham. W e Miller Board contradicted and repudiated the Ommission's ruling that the GDC 17 requirenent of an onsite AC power source _is applicable to all phases of LIICO's proposed low power proposal.
3 Sird, the Miller Board's ruling, adopting LIICO's argtanent thst the re-4 quirements of GDC 17 would be met during its proposed Phase I and Phase II, ig-notes the plain language of that criterion. W e first sentence of GDC 17 states:
An onsite electric power systen and an offsite electric power systen shall be provided . . . .
(enphasis added). %ere is na operable onsite power system at Shoreham. All the Miller Board's words about LIICO's supposed "cx2nplinnce" with GDC 17 in re-ality constitutes a challenge to GDC 17, since they anount to nothing but a re-hash of LIICO's view that despite the plain words of GDC 17, an onsite electric source does not have to be provided in order to obtain a license. %e Ctmnis-sion properly rejected that challenge to the regulations in its May 16 Order. S /
his Appeal Board must do the same thing aM reverse the Miller Board's errone-ous Phase I and II ruling.41/
g/ Indeed, the Miller Board's Septenber 5 ruling is reniniscent of its April 6,1984 Order, which the Ccmnission reversed, in which it read GDC 17 out of the regulations by Ming" the GDC into Section 50.57(c). Clear-ly, what was " harmonizing" then became " implication" and " interpretation" in the September 5 Order.
I 41/ Clearly, the argtsnent that because AC power is allegedly not necessary dur-ing Phases I and II, non-corpliance with GDC 17 does not matter (see Septenber 5 Order at 7-8), must be rejected. he same argunent could be made, for example, to support a low power license request even if the pri-
, mary containnent of a plant were not canpleted. Since there are no fission products in the core during fuel loading, arguably there is no need for a i
- - (Footnote cont'd next page) '
< a
, - . . - - - - , - - ,. ,r. , ,..,,--r. -- , ~--r.-+-- - - . - , . , - , , - - - - - , - - -
e- .
Eburth, the Board's September 5 Order is erroneous because it conpletely ignores the fact, fully briefed by the County and State, that the Conrnission has no authority to issue the licenses requested by LIlCO for Phases I and II. his violates the fmdamental requirement that adjudicators address the issues raised, confront the argtanents made by the parties, decide the issues, and pro-vide a meaningful explanation of the reasons for the decision. See Public Service Co. of New Hangshire (Seabrook Station, thits 1 and 2), AIAB-422, 6 NRC 33, 40-42 (1977). 'Ihere is thus no adequate Iredicate - no basis - for an NRC
. decision on LIICO's request for a Phase I and II license. Consequently, it is necessary for this Board to make a de novo review of the merits of the argtznents made by the County and Stiate with respect to the issue of a Ihase I and II li-cense, so that a decision Iroperly can be rendered. We outline the argtunents
! briefly below.
t.
In its request for issuance of a license for Phase I, LIICO stated that during " Phase I" it intends to load fuel into the reactor, and to perform vari-aus procedures, involving the loaded fuel, described as " core verification."
Phase I Motion dated May 22, at 2. According to LIIfD, during Phase I "the re-actor will not be~ taken critical." Statement of Material Facts attached to
-Phase I Motion, para. 5. Indeed, throughout Phase I, the pressure vessel will be mcovered. 'Ihus, if all goes acconiing to plan during Phase I, no power would or could be generated by the reactor.
-(IbutimYun cont'd fran previous page)
, containment structure. Ee proposition of issuing a Phase I/II license to
- a plant with no contairrnent is, analytically, no different frczn the propo- ,
sition adopted by the Miller Board with respect to Shoreham with no onsite power systern. ,
l i -
i
, - , . , _ , _ . . - , . . . . . . . _ . - . , _ _ . _ , _ , _ - - - . . . . . _ . _ _ , ....__-.-.-.._,_. _ ,,-...._. _ .,. _._ ,~._
9 6 It is clear that none of the activities conternplated during Phase I can be said to constitute " operation" of the Shoreham reactor. Although fuel will be loaded into the core and certain manipulations performed, and although during and follcwing Phase I the reactor will be closer to being ready for future operation, the Phase -I license which r TTf'D seeks is a "no power" license that is noWhere authorized or contenplated in the NRC's regulations or the Atcmic Energy Act. Similarly, the so-called Phase II license is also not an operating li-cense, since in Phase II LIICO proposes only to perform cold criticality testing, a step which again only brings the reactor closer to being ready for future operation. Accordingly, the cannission has no authority to issue the li-cense that is requested by LIICO for Phases I and II and thus the Miller Board's Order re'rrwxling a Phase I and II license nust be stumarily reversed.
In the (bunty/ State June 13, the lack of authority for issuance of a ."no
. power" license was thoroughly discussed. However, the Miller Board never even alltried to the isstie in any of its orders, much less confronted the County / State arguments. Since the Board has reccmnended approval of a Phase I/II license, it effectively has rejected the County / State positicn. However, under-settled NRC law, the Boctrd was required to explain why it rajected the County and State po-sition. See Public Service.(b. of New Hampshig (Seabrook Station, Units 1 and 2), AU4B-422, 5 NRC 33, 40-42 (1977) . 'Ihe Miller Board unquestionably violated this longstanding rule, as well as the NRC's directive in the May 16 Order to cc:xiuct the proceeding in accordance with the NRC's rules. This alone is suffi-cient basis to reverse the Septerter 5 Order.
'Ihe Atonic Energy Act contenplates the issuance of only construction permits and operatirg licenses for nuclear reactors. 'Ihere is no authorization
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in that Act for the issuance of a license to load fuel, or to manipulate a F loaded core, as an end in itself without operating the reactor. See 42 USC
$ 2133 (authorization to issue ccamercial licenses pursuant to { 2131 et _sg.);
} 2232 (requirenents of license applications for "a construction permit or an operating license"); and { 2235 (granting of construction permits, and granting of a license "upon finding that the facility authorized has been constructed and will operate"). And, the legislative history of the Act provides no indication that any such non-operating license was contemplat :d, intended, or authorized by the statute. What T.TTN requested and the Miller Board agreed to, therefore, has no foundation in the Atcmic Ehergy Act.
Similarly, the Omnission's regulations, which implement the Atonic Energy Act, authorize the issuance of only construction permits and operating licenses
- with respect to nuclear gewer plants. See, e.g., 10 CFR $$ 50.23, 50.30, 50.57.
'Ihe regulations do not even mention - let alone authorize - the issuance of a license to a holder of a construction permit for the purpose of using but not operating a crmnercial power reactor. 'Ib the contrary, the regulations clearly contemplate only two types of licensing: the issuance of a construction permit and the issuance of an operating license. See, e.g., 10 CFR { 50.33 on contents 1
of applications (references only ecmstruction permits and operating licenses),
and 10 CFR $ 50.51 on duration and renewals of licenses ("Where the operation of a facility is involved . . . [and] Where ecnstruction of a facility is in-volved.").
For example,10 CFR { 50.55(d) provides:
At or about the time of ccmpletion of the construction or modification of the facility, the applicant will file any additional information needed to bring the criginal applica-tion for license up to date, and will file an application for an operating license or an amendment to an application 4 g-[2 y -
+ y -.p.,p.., y - --+ . --y - - + < y -w-- rg --
we- g--+- -, y
n 's i
for a' license to construct and operate the facility for the t l
issuance of an operating li'canse, as appropriate . . . .
(emphasis added). Similarly, Section 50.56 states in pertinent part:
, Upon cmpletion of the construction or alteration of a fa-cility, in capliance with the terms and conditions of the construction permit . . . the atsmission will . . . issue a license of the class for which the construction permit was issued . . .,
-and,Section 50.57 follows with: ,
Pursuant to $50.56, an operating license nay be issued by the Chrunission . . . upon finding that: ,
(1) Construction of the facility has been substantially cm pleted . . . and (2) The facility will operate . . . .
(enphasis added). The fact that Section 50.57 provides for both 1cw power and full power licenses does not change the limitation of authority, set forth in
- tMit section, to the issuance of only licenses for operation.
Clearly, if the NRC had been authorized by Congress to establish an interim i "no operation" or "no power" stage in the licensing process between construction cmpletion and low power operation, the Omanission could have done so in its
,(
c ci regulations. Pursuant to its authority under the Atanic Ehergy Act, the Ocmunis-
%,fF sion has created in its regulations an elaborate scheme of specific licenses for.
TyJ '
d?? 1 p particularized activities, such as licenses concerning by-products,10 CFR Parts
- 2
'30-33 and 35, licenses concerning radicgraphic operations,10 CFR Part 34, li-censes concerning source materials,10 CFR Part 40, licenses respecdng the packaging of radioactive materials for transport, 10 CFR Part 71, and licenses concerning the storage of spent fuel in indeperdent spent fuel facilitie.s,10 CFR Part 72. The fact that this extensive licensing schane does not incitde provision for a license limited to loading fuel and the other no power h'
,,.,.j-
. - , . . _._..,___..__.___,,,,,._..m , , , . , _ , , _ _ . _ , , _ _ , _ , , , . ,,_._..,,___,,,.m_,__,,_,,,,_.,..,,_- ., ,-
. s l
l activities included in the Phase I and Phase II licenses approved by.the Miller Board is further evidence of the (bmission's lack of authority to issue such a licensed 2/
Mus, LIICO's No Power License request and the Miller Board's Order approv-
. ing that request fragmented invu.y=rly the Ocnnission's licensing Irocess into the smallest particle of a license that LIICO had a chance of getting. S e goal i . .
- of the Miller Board, therefore, was not to ccuply with or apply the mandatory t
two-staged licensing process which Congress and the NRC have established, but rather to ciretanvent that process by adding more licensing stages which dilute the stbstance of the central issues. Condoning this kind of ciretanvention of the regulations would tmdermine the licensing process itself, and wouli invite applicants to custcmize their license requests in any piel fashion that suits their mcznentary ends. We Miller Board's Septernber 5 Order approving i
LIICO's Phase I and Phase II license request should be reversed.
42/ We note that the alleged " precedents" cited by LIILO in support of its no power license request in fact fail to support the legality of the Miller Board's action. First, Pacific Cas & Electric Co. (Diablo Canyon Nuclear ~
Power Plant, Units 1 and 2), CLI-83-87, 18 NRC 1146 (1983), is conpletely i
distinguishable: the Ctmnission had already granted an operating license; the operating license had been suspended; and the Ctmnission ordered a staged reinstatement of the license in the context of an enforcement m - W irr.. Second, the Licer. sing Board decision in Virginia Electric aM Power Co. (North Anna Pbwer Station, Uhits 1 and 2), IBP-77-64 6 NRC 808 (1977), also constitutes no precedent here. bb party contested, and no portion of the Board's opinion concerns, whether a "no power" license is legal under the Atanic Energy Act or.the NRC's regulations. Bus, the j, issue raised herein is one of first inpression.
Finally the Miller Ibard's September 5 Order relies upon the Staff's action
- , in letting Duke Power load fuel and conduct pre-criticality testing at Ca-tawba. Septenber 5 Order at 10. Our understanding is that at Catawba the ,
- intervenors agreed to such a license and there was no adjudication cf the issue. M us, again this was not a contested case Where the no power 11-cense issue was squarely confronted.
1
. ._ _ . . . . . ~ , . _ _ _ . - - . _ _ . _ . _ . . _ _ _ - . . _ _ _ ~ _ . _ . . . _ . ~ _ _ . _ , - - _ . . _ .
F. Miller Board's Issuance of a Low Power License Violates Section 50.57.
LILOO's Phase I and II Motions were prenised upon the unavailability of the TDI diesel generators and the absence of any operable onsite AC power system.
As recognized by the Chmtission in its May 16 Order, and reflected in LIICO's Application for Exenption, the Shoreham plant configure 4.on postulated by LIICO for its proposed " low power" operation (including its Phases I and II activi-ties) differs substantially frm the configuration mandated by the regu]ations.
'1hus, in its Application for Exemption, LIICO stated that it seeks an exenption mder { 50.12(a) frm that portion of General Design Criterion 17, and frm other applicable regulations, if any, requiring that the TDI diesel genera-tors be fully adjudicated prior to conducting the low power testing described in LTmO's March 20 Motion . . . .
Application for Exenption at 4 (enphasis added). LILOO thus acknowledged that its preal to operate Shorehan with its unique electric power configuration rather than that required by the regulations and identified in the Shoreham FSAR, requires an examination of that configuration's conpliance with applicable regulations" in addition to GDC 17. Although LIICO failed to identify the "other applicable regulations" fran which it needed and sought an exemption, the state of coupliance of its newly proposed plant configuration with those "other regulations" raises factual issues which (1) were not identified or addressed in LIICO's stmnary disposition motions, and (2) under the regulations were required to be resolved prior to the issuance of the licenses for Ihase I and II sought by LIICO. 'Ihe Miller Board ignored this fact, even though LIICO's failure to couply with other regulations had been explicitly raised in the State / County June 13 filing, arx1 such lack of coupliance trade the approval of any license under Section 50.57 clearly erroneous.9/
43/ Here again, the Miller Board ignored the Seabrook requirement that the bases for a decision must be explained in a board's opinion.
As set forth in the Affidavit of Gregory C. Minor and Ihle G. Bridenbaugh, which was attached to the County / State June 13 opposition to LILCO's sumary disposition motions, the plant configuration proposed by LIILO does not satisfy the requirenents in the following regulations:
GDC 1 -
Quality Standards and Pecords GDC 2 -
Natural Phenmena GDC 3 -
Fire Protection GDC 4 -
Envirorynental and Missile Design Bases GDC 17 -
Electric Power Systens GDC 18 -
Inspection and Test of Electric Ibwer Systems GDC 33 -
Reactor Coolant Makeup GDC 34 -
Residual Heat Removal GDC 35 -
Bnergency Core Cboling GDC 37 -
Testing of.Energency Core Cooling System GDC 38 -
Cbntairrnent Heat Removal GDC 40 -
Testing of Contalment Heat Removal System GDC 41 -
Cbntainnent Atmosphere Cleanup GDC 43 -
Testing of containment Atmosphere Cleanup Systens GDC 44 -
Cooling Water GDC 46 -
Testing of (boling Water System Fart 50, Appendix B -
Quality Assurance Criteria Sce Minor and Bridenbaugh Affidavit at paras. 6-8. LIICO has not complied with GDC 1, 2, 3 and 4 because its proposed plant configuration does not include any safety-related, seismically or environnentally qualified onsite AC power sources. M. at para. 6. LIICO does not emply with GDC 17, 18, 33, 34, 35, 37, 38, 40, 41, 43, 44 and 46, because (a) there is no onsite energency AC power source in the proposed nee plant configuration, and (b) since there is no such source, the transfer frm offsite to onsite power cannot be tested as required by those criteria. 3 . at paras. 7, 10. Finally, the proposed alternate plant configuration has not been designed, installed, tested, nor will it be operated in accordance with the criteria set forth in Part 50 Appendix B. d . at para.
Ic 8.
l l
i l . - - . _- , - _ - - -
o .
On the state of the record before the Miller Board on Septenber 5, LIICO's non-cmpliance with these regulations was undisputed. 'Iherefore, under the May 16 Order, LIICO clearly was required to obtain an exenption fran conpliance with all the above regulations before any kind of license for Phase I or Phase II ac-tivities even arguably could lawfully have been approved. However, LIICO's sin-mary disposition motions and the Miller Boarc;a September 5 Order conpletely ig-nore this ' fact, by discussing only GDC 17. 'Ihis Appeal Board, therefore, must reverse the grant of LIILD's motions for failure to resolve the issues raised by LIIEO's non-carpliance with these NRC regulations.
Clearly, given the state of the record on Septenber 5, the Miller Board could not properly have made the findings required for the issuance of a license under Section 50.57. Indeed, the September 5 Order is totally silent on that subject, despite the unequivocal requirement in that section that Prior to taking any action on snch a notion [for a low power operating license] which any party opposes, the presiding officer shall make findings on the matters specified in paragraph (a) of this section as to which there is a contro-versy, in the form of an initial decision with respect to the contested activity sought to be authorized.
As detailed in the affidavit of Messrs. Minor and Bridenbaugh, which was sub-mitted to the Miller Board, the Shoreham plant with LIICO's proposed alternate AC power configuration, does not satisfy the requirenents set forth in Section
- 50.57(a).
Neither LIICO's March 20, 1984 Supplanental !btion for Iow Pbwer License, its Phase I and Phase II Summary Dirposition M3tions, nor the Miller Board's er-roneous Septenber 5 Order even address the Section 50.57(a) requirenents, or the Section 50.57(c) requirement that the E0.57(a) findings must be made.44/ Nhile 44/ In its original Motion for Iov Ibwer Operating License filed with the Brenner Board on June 8,1983, LIICO asserted that the only matters in con-(Footnote cont'd next page)
.- - ~ - - _ _ - __ _ _ _ _ - _ - . - _ _. -- . - .
o w it may generally be true that in the normal case, where a low power license ap-plication is based upon the same plant configuration as the full power license application (as was the version of LIIf0's mtion filed in 1983 before the fail-ure of the TDI diesels), prior Partial Initial Decisions may limit or cover the matters in controversy for purposes of Section 50.57(c), it cannot be denied that this is not the normal case. Here, LIIf0 has itself placed into controver-sy an entirely new proposal for the provision of onsite AC power in connection
~
with its most recent version of its low p3wer license motion and exenption re-quest.
Although aspects of prior litigation or decisions may be pertinent to LIIro's new prW plant configuration, they cannot be said to have eliminated frcm controversy in this proceeding the question whether the new configuration satisfies the requirenents set forth in Section 50.57(a). 'Ihus, by the mere fact of its having requested that a brand new, previously unheard of plant con-figuration be licensed for fm1 load and the activities proposed for Phases I and II, LIILO itself placed into controversy - indeed, it created - the factu-al issue whether the required Section 50.57 findings can be made with respect to (FvvLcte cont'd frm previous page) trovery (apart fran offsite emergency planning) for purposeu of Section i 50.57(c), were those identified in the contentions upon Which hearings were i held in 1982 and 1983. At the time of that filing - June 1983 - LIIDO l
may have been correct. Clearly, however, the facts subsequently changed as a result of the failure of the TDI diesels, the totally new alternate AC power configuration first proposed by rmm as a p of its Supplanental Motion for Iow Pbwer Operating License in March 1984, and the security-related concerns raised by the ne / AC power configuration. 'Ihe prior contentions, the litigation thereon, the Security Settlenent Agree-ment of December 1982, and the Partial Initial Decision issued in September t' 1983, did not consider - and could rot have considered - the nev AC power ,
configuration which LIIf0 first proposed as a basis for licensing Shoreham operation in March 1984.
~
(
L- _ _ . _ . . _ _ . _ - _ _ _ _
o -;
that'new Shoreham plant configuration. Ebr the reasons discussed below, there i
are material issues of fact concerning each of the Section 50.57(a) finlings which were never addressed by LIICO or the Miller Board, and accordingly, stuna-ry disposition on LIICO's license requests was clearly erroneous and nust be re-versed.
First, there was no basis upon Milch the Miller Board oculd find - nor did it - that construction of Shoreham has been substantially conpleted in confor-mity with the co t.ruction permit and LIILO's operating license application.
'Ihus, LIICO's operating license application, as detailed in its primary licens-ing document, the FSAR, includes the provision of onsite emergency AC power by three independent, environnentally and seismically qualified, safety grade, TDI diesel generators. 'Ihe FSAR postulates the inclusion of such diesels for both full and low power operation. 'Ihose diesel generators were to be designed and constructed in accordance with Part 50 Appendix B quality assurance and quality control standards, and were to be designed to meet the singla failure criterion.
See Minor and Bridenbaugh Affidavit, para. 4. LIICO's Supplemental Iow Pbwer License 2 tion requests a license for a plant without the diesel generators relied upon in the FSAR. Instead, LIICO proposes to use four mobile diesel gen-erators and one gas turbine, none of which is seismically or environnentally qualified, safety-grade, designed or constructed in accordance with Appendix B, t
or designed to meet the single failure criterion. '1he new LIIf0 prcposal is no-4 where mentioned in the FSAR. 'Ihus, the plant configuration proposed as a basis for the requested Phase I and Phase II licennes, is radically different fran the configuration postulated in LIICO's licensi. , 411 cation documentation. Ac-cordingly, the Miller Board could not, and did not, make the findings required -
under Sectione 50.57(a)(1), (a)(2), or (a)(3).
_.- . _ - , . . . . = . - . - . . - . - . - . . - - . . . - . - - . - -
- 0 -
Second, there was no basis upon which the Miller Board could find in its Septenber 5 Order - nor did it - that the issinnce of licenses for Phases I and II would not be inimical to the security of the public, as required tmder Section 50.57(a)(6). As set forth in Section II.B above, there were material facts in dispute concerning physical security, and pending security contentions before the Miller Board, at the time it issued its Septenber 5 Order. Clearly, there was no basis then upon which the Board could have made the required Sec-tion 50.57(a)(6) finding. Moreover, for the reasons we detail in Section II.B above, due to the Miller Board's unlawful dismissal of Intervenors' security contentions and erroneous and baseless actions reflected in its October 29 Deci-sion, there renains no basis in the evidentiary record to support those required security findings. - Accordingly, the Miller Board's approval of Phase I and Phase II licenses violated the clear requirenents of Section 50.57 and must be reversed.
III. CONCIMION I
For the foregoing reasons, the Miller Board's October 29, 1984 Decision, i
l and its September 5,1984 Order must be reversed.
l i Respectfully subnitted, l Martin Bradley Ashare i
Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 l
h ,
/
Ifett5ert. H. Brof j
Iawrence Coe I#fnpher Farla J. Ietsche KIRKPATRICK. & IOCI(HART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County
l g. b!
y '/'
Fabian G. Palcmino Special Cotmsel to the Governor of the State of New York '
Executive Chamber, Rocm 229 Capitol Building Albany, New York 12224 Attorney for Mario M. Cucmo Governor of the State of New York W her 11, 1984 P
hk / ' -
' ~
g+
UNITED STATES OF AMERICA-
-NUCLEAR REGULATORY COMMISSION
-Before the Atomic Safety and Licensing Appeal Board
)
In the Matter of )
)
'LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL- 4
) (Low Power)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County and State of New York Brief in Support of' Appeal of October- 29, 1934 ASLB Decision on LILCO's Exemption Request have-been served on the following this lith day of December 1934, by U.S. mail, first class, except as otherwise noted.***
- Alan S. Rosenthal, Chairman Edward M. Barrett, Esquire Atomic Safety and Licensing General Counsel Appeal Board Long Island Lighting Company-U.S. Nuclear Regulatory Commission 250 Old Country Road 20555 Mineola, New York 11501 Washington, D.C.
- Mr .- Howard A. Wilber
- W. Taylor Reveley III, Esquire Atomic Safety and Licensing Hunton & Williams Appeal Board P.O. Box 1535 U.S. Nuclear Regulatory Commission 707 East Main Street Richmond, Virginia 23212 Washington, D.C. 20555
- nr. Gary J. Edles Mr. Jay Dunkleberger Atomic' Safety and Li ensing New York State Energy Office Appeal Board Agency Building 2-U.S.' Nuclear Regulatory Commission Empire State Plaza Washington, D.C. 20555 Albany, New York 12223 J
t ' j Judge Marshall E. Miller, Chairman Stuart Diamond Atomic Safety and Licensing Board Business / Financial U.S. Nuclear Regulatory Commission New York Times Washington, D.C. 20555 229 W. 43rd Street New York, New York 10036 Judge Glenn O. Bright Stephen B. Latham, Esquire Atomic Safety and Licensing Board Twomey, Latham & Shea U.S. Nuclear Regulatory Commission Washington, D.C. 20555 P.O. Box 398 33 West Second Street Riverhead, New York 11901 Judge Elizabeth B. Johnson '
Oak Ridge National Laboratory Hon. Peter F. Cohalan P.O. Box X, Building 3500 Suff ik County Executive Oak Ridge, Tennessee 37830 H. Lee Dennison Building Mr. Brian McCaffrey Veterans Memorial Highway Long Island Lighting Company Hauppauge, New York 11788 Shoreham Nuclear Power Station P.O. Box 618 Martin Bradley Ashare, Esquire North Country Road Suffolk County Attorney Wading River, New York 11792 H. Lee Dennison Building veterans Memorial Highway MHB Technical Associates Hauppauge, New York 11788 1723 Hamilton Avenue Suite K Jonathan D. Feinberg, Esquire San Jose, California 95125 Staff Counsel, New York State Public Service Commission Fabian Palomino, Esquire 3 Rockefeller Plaza Special Counsel to the Governor Albany, New York 12223 Executive Chamber Stewart M. Glass, Esquire Room 229 State Capitol Regional Counsel Albany, New York 12224 Federal Emergency Management Agency l
Spence Perry, Esquire 26 Federal Plaza Associate General Counsel New York, New York 10278 Federal Emergency Management Agency Washington, D.C. 20471 Docketing and Service Section Office of the Secretary James B. Dougherty, Esquire U.S. Nuclear Regulatory 3045 Porter Street, N.W. Commission Washington, D.C. 20008 1717 H Street, N.W.
Washington, D.C. 20555 Nora Bredes
- Edwin J. Reis, Esquire Executive Director Bernard M. Bordenick, Esquire Shoreham Opponents Coalition 195 East Main Street U.S. Nuclear Regulatory Smithtown, New York 11737 Commission Washington, D.C. 20555 i
!? , ; ,
}
Atomic Safety and Licensing Board Panel -
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Eleanor L. Frucci, Esquire Atomic Safety and Licensing Board Panel U.'S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Joel Blau, Esquire New York Public Service Commission The Governor Nelson A. Rockefeller Building Empire State Plaza Albany, New York 12223 Mr. Martin Suubert c/o Congressman ~ William Carney 1113 Longworth House Office Bldg.
Washington, D.C. 20515 l > _
Nd4 #
KarkaJ. Lets e KIRKPATRICK & LOCKHART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Date: December 11, 1984 t
- By Hand
- By Federal Express
- The attachments to the Brief are being served only on Docketing and Service, the Appeal Board, the NRC Staff and LILCO.
J
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4 ,
) (Low Power)
(Shoreham Nuclear Power Station, ) ;
Unit 1) ) [
) L
) :
1 SUFFOLK COUNTY AND STATE OF NEW YORK BRIEF IN SUPPORT OF APPEAL OF OCTOBER 29, 1984 ASLB DECISION ON LILCO'S EXEMPTION REQUEST ;
e ATTACHMENTS
~
I t
Fabian G. Palomino Herbert H. Brown Special Counsel to the Governor Lawrence Coe Lanpher of the State of New York Karla J. Letsche Executive Chamber, Room 229 KIRKPATRICK & LOCKHART Capitol Building 1900 H Street, N.W., Suite 800 1 Albany, New York 12224 Washington, D.C.
Attorney for Mario M. Cuomo Attorneys for Suffolk County Governor of the State of New York j December 11, 1994
-~ . _ . . _ _ _ _ - _ _ _ - . _ _ _ _ _ _ . - - _ - _ _ _ _ _ - _ . - - - _ - _ - - . _ _ - _ . _ _ _ _ _ _ _ . - , _ _ _ _ . . _ _ _ _
O ATTACHMENT 1
ATTACHMENT 1
.+
UNITED STATES OF AM, ERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
) Docket.No. 50-322-OL-4 (Shoreham Nuclear Power Station, ) (Low Power)
Unit 1)- )
)
)
TESTIMONY OF MICHAEL D. DIRMEIER AND JAMSHED K. MADAN ON BEHALF OF SUFFOLK COUNTY I. STATEMENT OF QUALIFICATIONS Q. Please state your names and occupations.
A. My name is Jamshed K. Madan and my business address is 456 Main Street, Ridgefield, Connecticut. I am a principal in the management consulting firm of Georgetown Consulting Group, Inc.
My name.is Michael D. Dirmeier and my business address is 456 Main Street, Ridgefield, Connecticut. I am a member of the firm of Georgetown Consulting Group, Inc..
Q. Please describe the general nature of your firm's services.
O I
LILCO's financial condition, external financing is not presently available, and the Company's current estimates i
4 show that it will run out of cash in September 1984."
(Position Paper at 1). Additionally, the Position Paper reveals, again for the first time, that additional auster-
~
ity measures would not suffice to avert bankruptcy.
"Other sustarity measures and suspension of preferred dividends cannot solve LILCO's fin.ancial crisis, nor can they avert the threat of bankruptcy." (Position Paper at 47).
t Q. How is the public interest affected by the austerity pro-gram? . ,
l I
A. At December 31, 1933, LILCO had 5,947 employees. The aus-terity program eliminated 741 LILCO positions and 245 jobs with outside contractors. This represents a 12.5 percent i
, reduction in presumably needed and necessary positions.
. There can be no question that this action reduces LILCO's i
l ability to provide safe and adequate service. The public
- interest is directly affect 2d by any event that reducas that ability.
Further, the Position Paper reveslad that LILCO's f
( customers are 31 ready suffering as a result of the l -
.41 -
1
Company's financial problems. In LILCO's words, "The ,
effects of LILCO's financial crisis are presently being suffered . . . by its customers, who are subject to longer service response times and reduced customer service und,er the austerity plan." (Position Paper at 46).1/ The grant of an exemption would only further the adverse im-pact on LILCO ratepayers: low power operation at an early date in :he midst of the financial crisis would lead to more nuclear expanditures and less resources to be spent for custo's.er service. This not in the public interest.
P Thus, LILOO is at reduced service levels, having cut back'on current operation and maintenance programs in order to conserve cash. Apparently, not even Shoreham was exempted from austerity, since the Appendix to the Posi-tion Paper shows that austerity shifted 550 million of capital expenditures at the unit from 1984 to 1935.
Q. Is your conclusion regarding the public interest in !
present low power testing affected by consideration of I
7/ In addition, LILCO's counscl has stated "LILCO is now as-
~
suring safe and adequate service for tne short run -- not the long haul." (June 21, 1934 letter from Gerard A.
9aher, Counsel for LILCO, to !!on. Frank S. Robinson, Ad-ministrative Law Judge, NYPSC, attaened hereto as Attach-ment 9 ) .
42 -
what might happen if Shoreham goes into low power testing but fails ultimately to receive a full power license?
'A. No, it is not. Our conclusion regarding near-term low powe. testing versus testing at a later date after diesel uncertainties are cleared up hinges on LILCO's current cash situation and financing capability, its low capabili-ty to deal with contingencies, and the grave uncertainties resulting from the Nine Mile Point No. 2 default and the possibility that'Shoreham costs will'not be recovered. In addition, however, we believe that if Shoreham is allowed to undergo testing and then does not receive a full power license, the result would clearly be a public detriment approaching, if not exceeding, $100 million.
Q. How do you compute the $100 million detriment from low power testing without subsequent full power operation?
A. Before discussing the computation of this amount, it should be recognized that if Shoreham does not achieve i commercial operation, it will provide no benefit to the Company's customers from low power tasting. However, if low power testing is permitted and Shoreham does not oper-ate. commercially, a new economic detriment is created.
l-j I
L .
i i
l The tangible economic costs resulting from low power, i
testing,.with subsequent abandonment, are estimated to be H at least $100 million. This is composed of the following I
elements: .
- 1. Reduction in salvage value of the Shoreham plant, and in the value of nuclear fuel.
- 2. Increased costs of decommissioning an irradiated nu-clear facility.
- 3. Increased costs that will be incurred in handling and storing high level (fuel) waste and low level nuclear
' reactor system wastes.
- 4. Reduction in reclamation value of the Shorenam site, while radioactive materials are stored.
- 5. The increased costs incurred to perform low power
- testing activities will, themselves, have been l
l incurred with no benefit.
I
. Q. What is your understanding of the effect of low po.ver testing on Shoreham's salvage value and nuclear fuel?
8
- *4 -
8 A. The state of the nuclear power industry in the United States is well known, with many plants having been abandor.ed, so there is some question as to whether there would be significant salvage proceeds from Shoreham rela-tive to its S4.1 billion cost. However, there should be no question that the salvage proceeds would be reduced once the nuclear reactor internals and piping are irradi-ated.
In addition to the irradiation of the nuclear reactor internals, low power testing would also involve irradiation of the initial nuclear fuel load. LILCO's Office of Engineering Report indicates that "I ..Shoreham receives a low power license and operates before it is l'
abandoned, there would be no salvage'value for this core."
(p. 22 of "Shoreham Oparation versus Abandonment.") The ,
cost in terms of lost nuclear fuel value is estimated at
$70 million. ,
Q. How would low power testing affect the costs of decommissioning Shoreham?
l A. At the present time, de understand that no portion of Shoreham hos been irradiated. Consequently, dismantling it can be performed using conventional poser plant
-a . - - , - - _. - - - - , . - . , - , . , , . , - , . . - , . , - . . - , , . , , , , , , -
techniques. After irradiation, even at low power levels,,
it would be necessary to emp1oy increased safety measures ,
~
- during the plant's dismantlement, in order to control releases of radioactive materials to the environment and ,
~to limit worker ~ exposure. Constant monitoring of the plant and workers would become a necessity. In.the PSC phase-in hearings, LILCO estimated that the total cost of decommisioning (assuming full power operation had occurred) would be $407 million in after-tax dollars at the expiration of the-plant's book life. This equates to.
approximately $130 million in today's terms. We have no
" information as to how much of that $130 million cost is due to the need to deal with irradiated fuel and compo-nents as opposed to dismantling the plant if it were never irradiated. Although the cost of decommissioning a plant that nas operated only at 5 percent power would be less
-than tha; of a plant that-had operated at full power, de
-' do not know the point of the differential. Thus, the cost of decommissioning Shoreham following 5 percent operation would be some number lower than $130 million in today's-r terms.
Similsely, it is difficult at this time to estimate tne lost value of the Shoreham site during the pariod in 46 -
y which radioactive materials would have to be stored there. u It is our understanding that 'the federal government repos-itory for. nuclear wastes will not be ready until late in-the 1990's, so it is likely that the period of storage, and thereby the period of lost value, is in the 15 to 20 year range.
Based on the preceding -- nuclear fuel loss, salvage i loss, decommissioning and decontamination, and storage --
we believe the economic effect of testing without operation could easily exceed $100 million.
i
,. Q. Please summarize your conclusions.
i A. In our opinion, there is a 549 million economic detriment associated with accelerating low power testing of Shoreham !
- by three months. In addition, the public will be ad- l
\
versely.affected by allowing LILCO to proceed with low power testing in the near term, so long as LILCO's finan-1 cial future is so questionable as it is at the present time. Finally, so long as there is serious question as to I '
- whether Shoreham will receive a full power license, receipt of a low power license is not in the public inter-est.
t e 47 -
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ATTACHMENT 9 O
M AMER Cr DADINECZ. P.C. .
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. ,oior=*==un4vrwuz SAROSN Cf?Y. NEW YORK 19..O -
s.1 324. 444 SEIAs A. MA Est D&We. M.MA.aa.a n.. An. w. sa en- cw c n Sa
.. _ June 21, 1984 ca m.
Hon. Frank S. Robinson Administrative Law Judge.
Public Service Comunission Empire State Plaza Agency Building No. 3 Albany, New York 12223 - .
Re: Case 28553 .
Dear Judge Robinson:
At the June 12 hearing Company witness Mr. Sideris testified that LILC0's updated current cash flow p ojections would be available shortly (Tr. 4590).- Those' pro actions, in the format- .
of Exhibit 119 and using the same underlying asstssptions, are a ppended hereto as Attachment A. In stan they show the following changes in LILCO's indicated cash deficits for the remainder of
- 1984, assuming the company's total rate relief request for $281 million becomes effective October 1, 1984
Month-end Cash Deficit Exhibi.e 119 Attactunent A September $(17.3) million $(43.3) million October ( 8.8) million (28.6) million November 14.1 million (15.2) million
- December (43.8) million (60.9) million l
Aside from substitution of actual data for the April and May estimates in Exhibit 119. the changes reflected'ln Attachment A f are principally due to the matters Mr. Sideris addressed in his cross-examination i.e. , fuel and interest costs. Other, more minor, changes are~adHressed in the Explanatory Notes to the Schedule in Attachment "A".
Very truly yours, l
fbu,,(YY Gerard A. Maher l GAM /sd cc: All parties-i l
- t Attachment A h
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4 E EXPLANATORY NOTES 7 RECEIPTS Line.2 of Page 1 "Other Non-Financing Receipts" for 1984
.shovs'these receipts are now expected u be $5.5 million more than. anticipated previously, partly due to increases in interest rates and partly due to repayments to LILCO by memberso[ftheTDIdieselemergencygeneratorownersgroup.
The changes in the 1987 estimates on page 2 of Attachment A are primarily due to changes in interest rates and , reflection of payments from the Nine Mile Point II
, Construction Trust for borrowings from LILCO. There is a corresponding increase in Line 14 "Nine Mile Interest" disbursements.
( i l = DISBURSEMENTS Line 4.of Page 1 " Fuels" shows disbursements to be greater-than previously expected (Exh. 119) by about $18 million for m p .;. 1984 (see, Tr. 4571). This was caused primarily by a refinement of the prior estimates for fuel supplies needed to satisfy the expected fuel consumption for anticipated v sales ($14 million of the change occurred in the month of May). This revised fuel expense does not reflect any change in forecasted fuel consumption or sales. Thus, chere is no increase in anticipated revenues in Line I caused by t he refinement in the " Fuel" disbursements. T l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of .
. Docket No. 50-322-OL-4 LONG ISLAND LIGHTING COMPANY . (Low Power)
(Shoreham Nuclear Power Station, . Unit 1) . TESTIMONY OF RICHARD KESSEL ON BEHALF . 4 OF THE STATE.OF NEW YORK 9 Dated: July 13, 1984 Albany, New York RICHARD M. KESSEL
- EXECUTIVE DIRECTOR NEW YORK STATE CONSUMER PROTECTION EOARD 99 WASHINGTON AVENUE ALBANY, NEW YORK 12210 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of .
. Docket No. 50-322-OL-4 LONG ISLAND LIGHTING COMPANY . (Low Power)
(Shoreham Nuclear Power Station, $ Unit 1) . TESTIMONY OF RICHARD KESSEL ON BEHALF OF THE STATE OF NEW YORK Q. - Please state your name. , , A. Richard Kessel. Q. By whom are you employed and in what capacity? A. 'I am employed by the State of New York as the Director of
, the state Consumer Protection Board ("CPB").
Q. Please describe your educational background, employment history and responsibilities as CPB Director? A. I have annexed a biographical sketch to this testimony l which explains my educat,ional background, employment I history and role as a Long Island consumer advocate. As Executive Director of the CPB I am responsible for the development and implementation of various energy and other consumer related programs and policies before regulatory, legislative, judicial and public forums. I am also resporsible for the development of consumer education ' l programs and the preparation of educational materials to L. '~
guide. consumers in making economically sound decisions. i In my role as Executive Director of the CPD, I have been integrally involved in developing the CPB's position in 4 the Shoreham Prudence - Phase II (Case No. 27563), the-Shoreham Ratemaking (Case No. 28252), and the current Long Island Lighting Company, Inc. (LILCO or the Company') Rate (Case No. 28553) Cases. I have also written many articles and publicly stated my position regarding LILCO and
.Shoreham related issues. The most recent was an extensive Op Ed article contained in the June 27, 1984 issue of Newsday, a Long Island daily newspaper.
4 Q. What is the purpose of your testimony? , A. LILCO has requested an NRC exception from a rule which normally requires a nuclear power plant, even operating at low power levels, to have a fully qualified and dependable' [ i onsite electric power system. I also understand that LILCO's request for an exception is based upon a special NRC rule which indicates that the "public interest" must be . considered in an exemption proceeding. My testimony states my belief, and that of the State of New York, that 4 approval of such an exemption is not in the public interest. Q. What is your understanding of LILCO's exemption request? . A. I understand that LILCO seeks NRC permission to commence testing Shorcham at up to 5% power without a fully 2
~ . - _ _ . _ _ , - _ - _ . . . . _ . , _ . _ _ .
- i. ,
. qualified'onsite power system. Instead, LILCO proposes to use its existing offsite power system, enhanced primarily
- by the addition of a 20 MW gas turbine and four 2.5 MW mobile diesels manufactured by the Electromotive Division of General Motors. Neither the GM diesels nor the gas turbine is fully qualified for nuclear service as "onsite power"; hence, LILCO has sought the instant exception.
f Q. What is your understanding of. the alleged benefits LILCO contends will result from granting its exemption?
~ A. These " benefits" are discussed in LILCO's May 22, 1984 Application for Exeniption. LILCO has stated that the entire low power testing program, i.e., from fuel load to testing completion, will be completed within *2 to 3 months. If the Company receives an exemption, LILCO contends, it may be able to achieve commercial operation 2 t to 3 months earlier than would have been the case without an exemption. This LILCO contention is based upon two speculative assumptions. First, that the Company will be able to convince the NRC that the serious problems which j have plagued its onsite power system, i.e., the Transamerica Delaval, Inc. ("TDI") diesels, are resolved.
Second, that LILCO can secure NRC approval of its emergency offsite response plan. I also understand that i LILCO asserted that savings of $90 to S135 million can be attributed to favorable consideration of its exemption 1 3
-. _ . . ~ _ - . _ - a.. _ _ _ __ _ ..,_. __._ ,. _ . _ _ . . . . _ . _ _ _ . . _ _ _ . _
4 proposal. I have been advised recently LILCO has reduced its . estimate of this alleged saving from S8 to $42 million. Q. Do you believe that it is in the public interest.for LILCO i to be granted the requested exemption? I A. No. . Q. Please describe your reasons for opposing this exemption. i A. I have several bases for my opposition to LILCO's requested exemption. They are as follows:
- 1. It 'is not in the public interest to permit j
contamination of a nuclear facility before the uncertainties surrounding its future operation have been resolved. Th::: i: : Shaen by t.;i; :: :::x: th:t th: "nc rill :ll:r LILCC b
- Ch:::hn full p;;;; ;;;;; tin- li;;;;;. If Shoreham were to be operated at low power, and subsequently abandoned, costs would increase unnecessarily as a consequence of several factors. ,
%+bdg e y (g* g Tir;t, th: ::::t:: "10:201 tr cther equip ::t M prior Board will h=: S :=: :::t=i= t e, :=:: ; -
Tullog .s..s.. ... . .. >.. .... {ggj. _ - - . a. . , the value of the nuclear fuel will be . substantially reduced. Finally, the salvage value of irridiated equipment will be 4
l reduced. have been informed that the cos associated wit these three factors ha been j . estimated to be a roximately $1 million. I' -D00Yd rudng (Testimony of Michael irme r and Jamshad Y'2878 Madan who have filed te ony on behalf of ! Suffolk County i this ph e of this proceeding) ese increased co s would offset th possible fuel savings res ting i !. from n NRC exemption allowing l'ow pow i ! sting. , urthermore, additional direct an unn cessary economic costs may be absorb by LILCO customers if LILCO is al wed to . bbbY BOord recover e above described di nutions in g value from ratepayers. T se incremental costs would be . caused s ely by the approval of an expedited e ion to allow low power ,. testing. LILCO as c,onsistently taken the position th all Shore related costs have been in rred prudently d are recoverable l fro ratepayers whether Shore am does or does ot becomo commercially operabl
- 2. LILCO's rush to license Shoreham has already resulted in a decline of quality of service. .
The company expects either to implement or to l 5 l
~
i continue austerity reduction measures to i redu.ca costs by $60 to $80 million for the 12
. month period ending September 30, 1985. This sum - is an addition to approximately $30 to
. $40 million in austerity budget cuts already 4
-implemented by LILCO. All of these cost
- reduction measures have affected non-nuclear operations. LILCO's proposal to accelerate low power testing will probably require !
. additional funds which the Company will
- obtain by reducing non-nuclear related costs, j ,
thereb'y impairing its already diminished quality of service. This will cause further , l unacceptable deterioration of electric i service which is not in the public interest. l I believe the public interest will be better i served if LILCO incurred only those nuclear expenses related to its attempt to secure a I , commercial operating license by complying with normal NRC safety regulations.
- 3. York does not require Shoreham's capac
%aen by i
now nor ny years in the e. Thus, g g adequacy of genera capacity is not a Tr. Mo3 l concern . uld Shoreham's ommercial - l..
. ration date be delayed for an additiona 6
l c
T~ '
' s, 3 months. LILCO's Office of Engineerin in June 1983 publication entitled "SF eham b
+he Bcord Op'erati V. Abandonment (An Ec nomic
'U . Mo3
,- Analysis) " stated that Sho am is not .
purposes t required for capacity until 1994-1995. (Appe di B-1) The New York . Power Pool in its Range Plan - Electric Supply And D nd 1984- 00" has concluded that, on statewide basis, horeham is not requ ed for reliability purpos until the
! rn of the century. (pp. 32, 37-3
- 4. t makes little sense to allow LILCO t Strickers ey sup rt a request for an exemption to re eve the Board
- it f m economic problems cau d by Tr. A90$
managerial imprudence LILCO s acted the TDI diesels ich have alre caused the company's low po r testin schedule to slip significantly. The Cp and the County of Suffolk have sho , through testimony submitted in a New Yor Public Service Commission Sh eham prudence p caeding (Case No. 27563 ,' that LILCO's select on of and testin procedures regarding the TDI iesels wer deficient. It is certainly not i tne blic interest to reward LILCO with a 7
i emption t'o allow it to commence low r testing h unqualified on-site off-site den by
%e. Board , . power systems ticul when a prudent utility would ha apla the defective TDI diesels safety grade eq ' ent many rs ago.
- 5. It is inconsistent with the public interest to allow a financially weakened and nearly bankrupt company to operate a nuclear facility. Consumers' fears regarding [
l-Shoreham's operation will not be alleviated , with the knowledge that LILCO's financial
. i condition may preclude it from expending the funds necessary to operate shoreham safely at n ,
icw power. I note that these financial problems have recently caused a strike of the company's unionized employees. This
. indicates that the LILCo's precarious financial condition has undermined the -
reliability of its personnel and operations. It does not make any sense to impose additional safety responsibilities upon a company which.is so close to insolvency. In , the July 13, 1984 issue of the Wall Street Journal, LILCO's chairman and chief operating l 8
..v<-----w. .-.-.,,,...,,,o,,,,,,,,,y,,, _ _ , . _ , . . , _ . , _ . , __
officer, Dr. Catacosinos, stated that he "... cannot be as optimistic about the possibilities of averting bankruptcy as I was at our annual meeting in May". (p. 8)
- 6. LCO has mismanaged the entire Shorah g- .,
pr act. It is incredible that the Comp ny +he Boord can w seek to cut corners *by reques ng a Tr. Mog low po r license, even though it ca ot meet minimum fety requirements app cable to other nucle power plants. App oval of this exemption wi 1 neither still public confidence regar ng the i artiality of the NRC. nor allay th pub c perception that LILCO, a Company con dared by many to have mismanaged Shoreham r elved expedited and unwarranted regu tory tr atment. To grant
/
LILCO this ex iption, ther y allowing the Company to ircuitiou, sly eva normal NRC rules des ned to insure safe n lear power plant parations, would increas public conc n that Shoreham is less safe tha other nu ear power plants. This is not in the ublic interest and should not be permitte O. Does this conclude your testimony? A. Yes. 9
. 4 .
4
!A .
d uses* STATE OF MW Y0mst EXECUTNE DEPARTMENT STATE CONSUMER PPOTECTION BOARD RCHARD M. KESSEL
. CHAM ANO EXECUf1VE OsmECTOR NMPLY TO: 1 I mePLY TO:
90 WASM4sGTON AVENUE 290 SmOADWAv. tFTH FLOom ALSANY. MW vomst 12210 MW vomst. Mw voms icoot Citt 474 Mle (212) 947-4442 July 19, 1984 ALL PARTIES (Docket No. 50-322-OL-4) The enclosed biography was omitted from my testimony filed on July 13 in the above numbered docket. I apologize f ny inconvenience. n \re k O l 1
%)
\l i , ./
Richard M. Kesse Enc. -
STATE OF NEW YOmn ENECUTivE oEPARTMENT STATE CONSUMER PROTECTION BOARD
. menyt* RICHARD M. KESSEL U anneta 8" *"***""* " ** "****'*""""" EXECUTIVE DIRECTOR new voan. New voan ,"oop usa =v. wew voan ime 9123 90FM (Stel 474 3814 BIOGRAPHICAL SKETCH Richard M. Kessel of Bellmore Long Island, was appointed by Governor Mario M.. Cuomo as Executive Director of the New York State Consumer Protection Board in Janaury of 1984 and confirmed by the Senate in February. Kessel is well-known for his consumer advoc,acy on Long Island and previously served as a consultant to the Borough of Manhattan on utility rate matters. ,
i Since 1981. Kessel has been a member of the Board of Trustees at Nassau Community College. After being appointed by then-Governor Hugh L. Carey, Kessel led the Board of Trustees in adopting major reforms in the administrative practices of the college. Kessel ' introduced measures which banned uepotism on the college payroll, restricted the number of hours for which sdainistrators could receive extra compensation, and helped develop a reorganization plan which reduced the administratfon by one-third. A 1971 graduate of New York University, Kessel also attended Colgate University from 1967-1969. He received his Masters in Political Science at Columbia University in 1974. Kessel has taught consumer economics at Brooklyn College and has developed course outlines for such courses as: Introduction to Consumer Studies, Consurnar Resources and the Consumer and Energy. As a Long Island consumer advocate, Kessel was instrumental in having the Nassea County Board of Supervisors adopt consumer-oriented legislation including an item pricing law, a ban on multiple pricing
- and a requirement that all perishable foods be marked with the last date of sale. Kessel also led the fight to eliminate Nassau County's 37 sales tax on home heating fuels. .
Kessel has appeared before the New York State Public Service Commission on numerous occasions to advocate the interest of consumers. In 1980 he successfully petitioned the Public Service Com-ission to issue a policy statement allowing the introduction of evidence of
~
economic impact on ratepayers in all rate cases. Prior to that, Kessel convinced the Commission to, hold evening hearings in utility rate cases. He has actively intervened in the last five LILCO rate cases, the last four New York Telephone cases, the last three con Edison rate cases, and several generic proceedings. He was the first person to petition the PSC for both a management audit and a phase-in of costs for LILCO's Shoreham Nuclear Power Station. In 1980 Kessel made history by organising the first commuter strike against the Long Island Rail Road in response to massive breakdowns in service. He also gained national attention when he successfully sued the LIRR for failing to provide reliable air conditioning service during the summer months. That successful lawsuit, which was never appealed, established the right of commuters to receive a f air standard of service. Kessel, 34 years old, has also conducted many consumer surveys and studies which have helped inform consumers about their rights as well as marketplace conditions. His " holiday" surveys of prices for such items as Halloween Candies, Thanktgiving Turkeys, Valentine Hearts and Mother's Day Roses have been reportad throughout the nation. He has also revealed numerous consumer abuses including 'butterless' buttered popcorn, 'alcoholiess' apple champagne and ' leaded' lead-free gasoline. Kess'el is a member of the Board of Directors of the New York University Alumni Federation. He is also a member of the Board of Directors of the American Jewish Congress.. e a f 4
y r ATTACEMENT 3 I ( l
UNITED STATES OF AMFRICA NUCLEAR REGfiLATORY COMMISSION RFFORE THE ATOMIC SAFETY AND LICENSING BOARD
) '
In the Matter of )
)
LONG ISLAMD LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) ' Unit 1) )
)
DIRFCT TESTIMONY OP DAL? G. BRIDENBAUGH AND RICHARD B. HUBBARD ON BEHALF'OF St1FFOLK COUNTY I. INTRODUCTION On Mr. Bridenbaugh, please state your name, address, occunation and professional qualifications. Y A: My name is Dale G. Bridenbaugh, and my business address is 1723 Hamilton Avenue, San Jose, California. I am president of MHB Technical Associates. My qualifications are attached hereto as Attachment 1. Q: Mr. Hubbard, please ' state your name, address, occupation and professional qualifications. As My name is Richard B. Hubbard, and my buu...ess address is 1723 Itamilton Avenue, San Jose, California. I am vice-9 resident of MHB Technical Associates. My I qualifications are attached hereto as Attachment 2. l l
II. PURPOSE OF TESTIMONY 0: What-is the purpose of your. testimony? 4 A: .LILCO has souaht'an exemption from NRC regulations to
. permit low power operation in advance of any FRC decision
- on the adequacy of its onisite emergency diesel generators.
Under 10 CFR 650.12(a) and the NRC's May 16, 1984 decision (CLI-84-8), a relevant consideration is whether the public interest'and a balance of the equities are in favor of the grant of an exemption. Further, in its May 22 Application For Fxemption, LILCO has expressed the view that it is
-only due to problems arising during preoperational testing of the Transamerica DeLaval, Inc. ("DeLaval") diesels that the diesels have not yet been licensed. g Application fer Exemption at 25. ,
The purpose of our testinony is to summarize the results of an investigation we have undertaken into the facts and c:ircumstances involving LILCO's selection and procurement I of the DeLaval emergency diesel generators (" diesels") and + of the actions taken by LILCO in conjunction with the failures subsequently experienced with these engines. 9 t t 0
-_ . . . . . . _ . . . _ _ _ _ - - - . - - _ - _ _ . _ _ . - - _ _,-m..-----
were --ww ~
t o 0- In summary, what are'your conclusions?
- g At We conclude that the delays and costs associated with the Shoreham diesels are the responsibility of LILCO (or of L LILCO suppliers or contractors). These problems did - not only arise during preoperational testing. Rather, since L
1974 there have been repeated indications that there might be serious problems with the DeLaval diesels.- In our opinion, LILCO knew or should have known of these problems at an early date and should have taken steps to ensure r l- that reliable diesels were procured. LILCO failed to take i such steps. Such steps would have been to (i) commence a complete design review and revalidation program far in l advance of the September 1983 date when such a program ac-i i tually was started, thus laying the basis for potential repair and/or qualification of the DeLaval diesels in a l timely manner which would not necessitate application for l an exemptions or (ii) to procure replacement diesels at'a i far earlier date, thus having-reliable diesels on hand now instead of the Summer of 1995 when the Colt diesels are scheduled to be ready. Accordingly, it is our opinion that it would not be in the public interest and that a l-balance of equities would not favor the grant of an ' ' exception from applicable regulations when the primary l I e
c - reason that LILCO now seoks an exemption is because of its own failure to take reasonable steps to ensure procurement of reliable diesels at an earlier time.
~
O: Prior to seeking an exemption, how did LILCO propose to comply with GDC 17 during low power operation? A: Since January 1976 when the Shoreham FSAP first came out, LILCO has always relied for onsite emergency AC power on bhreeDeLavaldiesels. These diesels, as will be discussed later in our testimony, were' ordered from DeLaval in 1974 and arrived at Shoreham in 1976. They were stored for some period of time, and then installed. Turnover to the.startup organization for testing occurred
~in August 1980 for Diesel Generator 102, and in October 1991 for Diesel Generators 101 and 103. Intensive preoperational testing began in September 1982.1/
t 1/ Direct Testimony of William J. Museler and Edward J. Youngling, New York PSC Case No. 27563, November 4, 1983.
~ a Q: Tn a previous answer you referenced an investigation of LILCO's _h'andling of issues related to the DeLaval diesels.
-Please. explain.
A We submitted written testimony on February 10, 1984 in the ongoing proceeding before the New York' Public . Service Commission in PSC Case'No. 27563 (Phase II), a case designei to investigate the cost of Shoreham. The purpose of that . testimony was to examine the reasons for the dra-matic increase'in the estimated cost of the Shoreham Nu-
~
clear Plant, from an estimated $65-75 million'in 1966 to a January 1984 estimate of $3.877 billion or more. In preparing that testimony, we evaluated the amount of the cost increase that is attributable to LILCO's allegedly imprudent. responses to regulatory,' design, and technical problems. 'Among the issues addressed was how the cost of Shoreham was affected_by LILCO's procurement, installa-
. tion, and testing of the DeLaval diesels.
Our investigation concerning the costs' incurred at Shoreham consisted primarily of our participation in the PSC Phase II discovery process. We reviewed documents provided to Suffolk County and the Public Service Commission Staff by LILCO. In addition, we assisted
.y Suffolk County in the preparntion of interrogatories and e reviewed LILCO's responses to them. MHB representatives also attended and participated in many of the interviews that the Public Service Commission Staff and its consul-tants conducted with employees of LALCO and Stone and
.W ebster.(LILCO's Contractor Architect-Engineer). .
'In addition to our role in the discovery and testimo-ny phase of the Phase II proceeding, Gregory Minor and Dale Bridenbaugh of MFB also provided testimony regarding the likely cost and schedule to complete Shoreham in Phase I of that proceeding. Finally, since 1977 MHB has been consultant to Suffolk County in the Atomic Safety and
( . .
. Licensing Board proceeding to ~ determine Whether LILCO has met.tha requirements.necessary to-receive an Operating License, participating actively in the DeLaval' diesel pro-i ceeding,'among others. s -
i l- III. 'LILCO'S EMERGENCY DIESEL GENERATOR PROBLEMS l 0: Briefly describe the major problems LILCO has encountered recently with its DeLaval diesels. A: The three DeLaval diesels at Shoreham have experienced re-y peated deficiencies as set forth herein and in the i b
.>'+
t
l i Attachments. For example, operational problems with the diesels at Shoreham occurring a relatively short time prior to.the August 1983 crankshaft failure included cyl- l inder. head cracks,. rocker arm assembly hold-down bolt failures, turbocharger bearing failures, and cracks in the engine block casting. Further, LILCO was fined $40,000 by the NRC-during 1983 for its failure to follow required procedures during the preoperational testing of the die-sels. On August 12, 1983, during the testing of replace-ments for cylinder heads that had cracked, one of the three diesels, 102, exoerienced excessive vibration and-erratic load swings. On August 13, 1983, it was discovered that the crankshaft on diesel'102 was com-pletely severed. During disassembly of the diesels, the
- - crankshafts of the other two diesels were found to contain i .
cracks.. In addition, following the crankshaft failure in August 1933, other problems were subsequently revealed, including cracked connecting rod bearings and pistons.2/ i i 2/
~
Millard S. Pollock to Harold R. Denton, Ncv. 23, 1983,
.SNRC-986.
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Ultimately, 23 of 24 pistons in the Shoreham engines were found to be cracked.3/ In Fall, 1983, following the crankshaft failure, and in recognition of other operational deficiencies as set forth later herein which have occurred with DeLaval diesels, LILCO instituted a recovery program aimed at determining the cause of the crankshaft failure, correcting it, and attempting to ensure that other components of the Shoreham diesels would operate reliably in the future.4/ In our
-opinion, this recovery program came far too late in time.
O: Were the recent DeLaval problems you just described a comolete surp: ise or were these problems to have been ex-pected? 3/ LILCO Diesel Generator Status Report, November 17, 1983. 4/ Brian R. McCaffrey to Harold R. Denton, Jar.uary 6, 1984, Shoreham Diesel Generator Recovery Program Summary, SNRC-LOO 3. The NRC has also recognized the need for such a recovery program. Indeed, the NRC determined that a broad pattern of deficiencies in critical engine compo-nents has become evident at Shoreham and at other nuclear
- and non-nuclear facilities employing DeLaval diesels. The
( NRC now believes that the deficiencies stem from. I inadequacies in design, manufacture and quality control by DeLaval. Order Requiring Diesel Generator Inspection," Grand Gulf Nuclear Station, Docket No. 50-416, May 22, 1984. (In particular, see Attachment 4 thereto.) LJ
A:- The precise problems or failures which have been experi-enced in.the Shoreham i'eLaval diesels in the last year and a half were perhaps not expected. However, given prior _ events related to the diesels, serious problems cannot be deemed to have been a surprise. Indeed, the reported r cause of the current problems (discussed later in this testimony) can be traced directly-to failures that occurred early in the . design and manufacturing process.5/ l Q: How do these problems relate to LILCO's Application For l Exemption?
~
5/ For example, 7,ILCO. retained Failure Analysis Associates [ (" Failure Analysis") to investigate the August - 1983 crank-shaft failure.. Failure Analysis concluded that the crank-shaft failed becausc it was not designed to withstand the cyclic torsional stresses that would be experienced during The conclusion was reached, based thedieseg on a rels g'_gggration.
;impl: calculation, that DeLaval had
! Ocucc hans - _,
- mu dc ,oy misdesigned the crankshaft, leading to insufficient capac-W't^3 4 Ci ity to withstand anticipated loads. Emergency Diesel Gen-E erator Crankshaft Failure Investigation, Failure Analysis, October 31, 1983. LILCO attributed the crankshaft problem l to a design error in the torsional stress analysis performed by DeLaval. LILCO Diesel Generator Status Report, November 17, 19R3. As will be addressed later in this testimony, the LILCO and Stone and Webater audit of~
DeLaval in 1975 -did not even address the crucial area of
' design control. If it had, perhaps the design deficiency in'the crankshaft would have been a notice of the need for
- a. thorough design review.
L l
-A: . It is our position' that LTLCO was, in effect, responsible for- failing to detect these. deficiencies and for failing at a far-earlier date (i.e., well in advance of Fall 1993) to institute necessary steps to repair (if possible) or replace the' DeLaval diesels. Thus the need for LILCO now to seek an exemption is really the result of LILCO's own i
- fault. .Indeed, as set forth in the following portions of this testimony, our review indicates that from 1974 to 1983, LILCO's approach has been to treat the symptoms rather than the root cause(s) underlying the problems dis-closed in the design and fabrication of the Shoreham die-sels. Thus, there have been repeated problems with these diesels which put LILCO on notice far before Fall 1983 that-something was fundamentally wrong with its diesels.
LILCO ignored the warning signs and never sought'to deter- , mine adequately why the problems existed. The need for LILCO now to seek an exemption is a direct result of LILCO's failure to detect and remedy in a timely manner the broad pattern of deficiencies in the design and manufacture of the DeLaval diesels. O: Does the fact that LILCO initiated a program in Fall 1983 to attempt to mitigate and correct the problems with th'e DeLaval diesels change your opinion that LILCO's need for
an exemption is a result of LILCO's own failure to take appropriate actions at an earlier date' l A: No. The fact that LILCO has eventually begun to attempt to deal with the difficult (perhaps insurmountable) DeLaval diesel problems does not make its prior failure to act any less the cause of the problem in the first place. Our point is that it is not in the-public interest, and it is.not. equitable to reward a utility by waiving a compul-sory safety regulation, when the reason the utility is un-able to comply with that regulation is a result .of its own
' insufficient actions.
~
O: When did LILCO first become aware of the potential for serious deficiences relating to the DeLaval diesels? A: In 1974 LILCO was on notice that heightened QA/OC audit treatment of DeLaval would be necessary to ensure that a reliable and top quality product would be designed and manu factured . In fact,~ however, despite obvious warning signals, LILCO and Stone and Webster failed to implement l-an adequate QA/QC audit program for the design and l manufacture of the DeLaval diesels. L - _
.j i
20: Please state the basis (es) for your prior answer. A: The diesels supplied for Shoreham were DeLaval's first ever contract for supply of a diesel for a nuclear appli-cation. To the best of our knowledge, DeLaval had never even attempted to develop or implement a 10 CFR 50 Appen-dix,B OA program before 1974. DeLaval's newness to nucle-ar work and Appendix B QA matters, in our opinion, made it incumbent on LILCO or its delegate to pay close attention, from the beginning, to how well DeLaval.was doing in de-signing and manufacturing the Shoreham diesels. Indeed, the fact that DeLaval was new to the nuclear field made it j absolutely incumbent on LILCO to ensure that a stringent au.iit program was instituted to ensure that all nucl. ear requirements were met. In fact, however, LILCO did not institute such a program.5/ 6/
~
Since the Shoreham diesels were DeLaval's first attempt to design and manufacture diesels pursuant to the regulatory requirements of Appendix A and Appendix B to.10 CFR Eart 50, LILCO and Stone and Webster should have anticipated
" hugs" in the DeLaval QA program. Thus, Stone and Webster should have increased its audits of DeLaval activities during the design and fabrication of the Shoreham diesels because the need to detect and correct the " bugs" in the
'DeLaval QA/OC process was obvious. LILCO's failure to as-sure that this was done is another basis for our belief that LILCO's present need for the requested exemption is its own fault.
I
^ .
Thelpurchase order for the DeLaval diesels was issusi ihy5LINCO in May 1974 following a GA survey of the DeLaval shop ~ conducted by Stone and Webster on February 26, 1074.7/ The DeLaval OA manual had been reviewed by Stone and Webster one week earlier (on February 19, 1974) and had been found not to meet several of the regulatory re-quirements of Accendix B to 10 CFR Part 50. The major deficiencies discovered by Stone and Webster were that design control and a number of measures for vendor correc-tive action, OA record retention, and audits, were not addressed in the DeLaval manual.8/ It was not until March 14, 1974, that Stone and Webster determined that the DeLaval OA manual, as revised on March 1, 1974, was in compliance with the intent of 10 CFR Pa'rt 50, Appendix B. Based on the preceding, we conclude that the Stone
'and Webster shop survey should have put Stone and Webster and LILCO even more on alert (aside from DeLaval's lack of nuclear experience) in ear 1.y 1974 of the need to closely watch DeLaval's OA implementation. They did not. -7/ Stone and Webster Procurement Quality Control Survey of DeLaval, G. I. Beaman, February 26, 1974.
8/
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Stone and Webster Manual Checklist, DeLaval QA Manual dated May 1, 1970, Ellen O'Connor, February 19, 1974.
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The fact that the February.1974 shop survey was conducted on a OA manual and program which were in transi-tion should have led to a new survey and audits of OA implementation' shortly after March 14, 1974 when the QA manual was - found to be adequate or shortly after May 1974 when the purchase order was issued. This would have allowed an early judoment, during the key diesel design l l phase, regarding whether essential OA functions were being propet ly performed . LILCO failed to do any such audits in l a timely manner. Stone & Webster'did, much later, conduct an audit of DeLaval. However, the audit findings, the time of the audit, its scope, and the lack of additional audits, support our view that LILCO should be deemed to be respon-sible for the difficulties with the DeLaval diesels. This one audit of DeLaval by Stone and Webster was not conducted until October 28 to 30, 1975, more than 18 rnonuo\reNito months after the initial che,r cur :y that found DeLaval OA to be deficient and about 18 months after the purchase order had been placed. Reaudits of the corrective action m'easures required of DeLaval as a result of the October
~
1975 audit were performed on February 23, 1976 and June 18, 1976. In both the 1975 audit report and the February-1 reaudit, Stone and Webster auditors concluded that DeLaval had. failed to fully comply with the requirements set forth in its OA menual or with the regulations in Appendix B to 10 CFR Part-50. The three diesels were shipped to LILCO on the fol-lowing dates: diesel 101, February 27, 1976; diesel 102, March 27, 1976; diesel 103, May 14, 1976. There fo re , all three diesels were designed, fabricated, tested, and shipped prior to implementatic ' of the required OA measures, in effect without full regard for the potential impact of the identified discrepancies on the hardware. Indeed, even at the time of the first audit in late 1975, DeLaval's design and procurement activities .were .nearly complete, and the fabrication of components at the DeLaval casting and manufacturing facility was well advanced. Thus, in many rcspects, th,e Stone and Webster audit largely represented an after-the-fact evaluation which , - resulted in little or no effect on the Shoreham diesels. Rather prophetically, Mr. Bienduga, Stone and Webster Procurement Quality control District Chief, observed in a January 29, 1976 memorandum which concerned the October
- 1975 audit:
4
.I feel that DeLaval's response is too lit-tle too. late as the audit was conducted to verify compliance to the'P.O. and approved O/A program, not to upgrade their system for future work. We should either get a positive response as to what actions are
-being taken now or we should stop the joh!
Furthermore, there were significant limitations in
'the scope of the audit. conducted on behalf of LILCO by Stone and Webster. The 1975 audit, as well as the reaudits, investigated DeLaval's compliance with only 11 'of the 18 criteria of Appendix B: Criteria 4, 7, 9, 10 and 12 to 1R. The areas audited by Stone and Webster pri-marily involved procurement and fabrication. Critical areas including design control (Criterion 3),9/ procedur-al control (Criterion 5), and document control (Criterion
- 6) were not addressed in the Stone and Webster audit or-reaudits. Thus, during the entire course of DeLaval's de ,1gn and manufacture of the ' diesels for Shoreham, criti-cal Appendix B criteria were never audited by LILCO or its representative. Stone and Websters' failure to audit the DeLaval riesign activities, including the design verifica-
^
tion program, is a significant omission. Stone and 9/. We note that the critical crankshaft failure of August 1983 resulted from design errors. See note 4 in this tes-timony.
- 16 - ,
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I I l i Webster, in effect, delegated responsibility for design OA activities to DeLaval. Further, Stone and Webster failed to recognize early in th'e design and fabrication schedule the potential problems that DeLaval might confront in sup-plying its first diesels for nuclear application. Indeed, Mr. Bienduga came to this conclusion after the fact: My personal feelings regarding this reaudit is that too much responsibility has been given a relatively young,' inexperienced, quality engineering group. There seems to be passive acceptance by the Q/C Mgr. of-excuses and not enough supervisory follow up to get things done. Granted the LILCO order is their first 'nu-clear' contract and there are many ' bugs' to be ironed out but that doesn't help our situation unless the O/C Mgr. is'willing to take positive steps to get the ' bugs' out of the system.lO/ In light of DeLavals' failure to meet adequate OA standards in other areas, DeLaval's lack of nuclear expe-rience, and Stone and Webster's knowledge of such failure and inexperience, this was a particularly deficient action by LILCO's contractor, which supports our belief that the problems with the DeLaval diesels could possibly have been _ prevented by LILCO. 10/ Stone and Webster Interoffice memorandum, W. V. Bienduga, February 25, 1976. 17 -
0: What actions should LILCO have taken after the knowledge it gained or should have cained in the 1974-76 period? A: The serious deficiences in the OA implementation deficiences identified in 1974-76 should have alerted LILCO to the need to carefully assess the adequacy of these diesels at an early date. O: Did LILCO commence such an early reassessment program? A: No. As noted above, LILCO did not start such a program 6 until Pell 1983. Q: Between 1976 and the Fall of 1983 did LILCO acquire (or should it have acquired) further data to indicate the need for an early revalidation or diesel replacement program, which, if implemented, would have eliminated the need for LILCO to seek the instant exemption? A: Ye s . LILCO's experience with the DeLaval diesels commenc-ing in 1977 should have alerted LILCO at an early date to potential OA problems, so that a't an early date LTLCO should have taken steps to avoid the situation which it presently confronts. 18 -
t
'Q i:- ~
since-late 1977,. LILCO has discovered and repaired or R . sought. t'o remedy numerous problems with the Shoreham die-sels. For example, 21 problems with the diesels that l LILCO experienced prior to 1991 are set forth in a i January 15, 1981 letter from D.D. Terry of LILCO Start-Up to Mr. Taylor. The lettsr is appended as Attachment 3 hereto. These deficiencies also necessitated a number of ) Engineering and Design Coordination Reports (see Attach-ment 4-hereto) in order _to attempt to achieve engineering resolution of these problems, leading one LILCO employee to observe "we bought the low bidder." In addition, in 1983, Energy Consultants Incorporated conducted a. retrospective assessment for the NRC of selected operational problems identified in LILCO Defi-ciency Reports, Repair /Pework Requests, and failure reports issued by LILCO and DeLaval. Energy Consultants' report, issued prior.to the DeLaval crankshaft failure, concluded: A large number and variety of problems that have been experienced can be attributed to vendor workmanship. These errors, in con-
' junction with the problems identified dur-ing audits of DeLaval's Quality Assurance Program faudits/reaudits conducted October 1975, February 1976, and June 1976], indi-cate a weakly implemented Quality Control Proc am.
(Emphasis supplied). Energy Consultants also observed that: During 'the detailed review of various Defi-ciency Reports, Failure Reports and 4 Repair / Rework Requests, a significant number of problems or errors have been identified which seem to have occurred due-( to errors and incomplete or improperly com-
- pleted work by the manufacturer.ll/
Examples of specific problems with the DeLaval diesels that Energy Consultants concluded fell into tnis category are set forth in Attachment 1 of its report. Other documents also reveal a broad pattern of problems with the diesels. Indeed, even LILCO now asserts that: l Prior to the crankshaft failure, LILCO had experienced a number of occurrences at-i tributable to defectively designed or fab-ricated diesel generator components, including three leaking cylinder heads, de-fective jacket water pumps, leaking fuel. i oil injection lines, inadequate
- turbocharger thrust bearing lubrication, inadequate piston skirt to piston crown 11/' Energy Consultants Incorporated, " Witness and Evaluation of Emergency Diesel Generator Testing at Shoreham Nuclear Power Station for Nuclear Regulatory Commission, Region I Staff, Final Report of NRC Contract No. 05-82-249
_ Parameter Purchase Order No. NRC-IE-82/83, Task 38", July j 12, 1983, appended as Attachment 5. L : 20 - [
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attachment, broken rocker arm shaft bolts and' cracked subcover assemblies. While these occurrences were generally of the type experienced in the shakedown of large diesel engines, they appear, nonetheless, to be attributable to defective design or fabrication.12/ In our opinion, LILCO could and should have. recognized far before Fall 1933 that the DeLaval diesels were probably not reliable, .and thus, should have taken steps at an earlier time to remedy the diesel problem. However, LILCO failed to do so. Instead, it let the situ-ation deteriorate to the Doint of a catastrophic failure of the machines, and now seeks special treatment from the [ NRC. LILCO's failure to take timely early action to address the root causes of DeLaval failures is also reflected,in LILCO's failure to take heed of the significant NRC find-
- ings of deficiences in'the DeLaval OA program. For exam-ple, the NRC Staff has observed that "the number of minor problems experienced by the TDI machines in nuclear service appears to be abnormally high."13/ A summary of i 12/ Letter, E.M. Barrett of LILCO to Robert E. Smith, counsel for DeLaval, December 2, 1983, appended as Attachment 6.
13/ Nuclear Regulatory Commission Board Notification 83-160, October 21, 1983, page 1. Enclosures 2 and 4 to the Board (Footnote cont'd next page)
1 ooerating problems experienced with DeLaval diesels, which I was compiled by the NRC Staff, is appended to this testi-mony as Attachment 8.14/ In addition, during its vendor inspections in 1983, the NRC inspectors identified
" conditions which imply that portions of the DeLaval GA Program have not been carried out in accordance with the b provisions of lO-CFR 50, Appendix B."15/
Further, the NRC vendor inspection program previously had identified problems in the implementation of the DeLaval OA program. Beginning in 1979 and continuing through 1983, the NRC conducted nine inspections at DeLaval. Sixty-two instances of regulatory violations or nonconformances were documented.16/ This number of 4 4 (Footnote cont'd from previous page) Notification identify a number of problems that have occurred with DeLaval diesels over the last three years. It is appended as Attachment 7. 14/ DeLaval Diesel Generator Operation Experience,. handout prepared by the Nuclear Regulatory Commission at a meeting
~~
on DeLaval diesels held by the Staff in Bethesda, Maryland on January 26, 1984. Appended as Attachment 8. 15/ Nuclear Regulatory Commission' Board Notification 83-160, October 21, 1983, page 2 (attached as Attachment 7). The details of the allegations have not been revealed by the NRC to avoid cor.oromising the ongoing investigation of DeLaval being conducted by the NRC's Office of Investiga-tions. 16/ Nuclear Regulatory Commission Vendor Inspection Reports (October 14 to 17, 1980), issued January 22, 1981; 81-01, (Footnote cont'd next page) 1'
- - . - - ... . . - . -. .- .. . . . . - ~
L L
' problems in.the DeLaval GA program, many of which remained uncorrected. over three years a fter the completion of the shoreham. diesels, further demonstrates that the DeLaval OA process was suspect and that LILCO, far before Fall 1933, should have recognized the unreliability of the DeLaval diesels and taken steps to institute a comprehensive revalidation program or to replace them completely.
Attached to this testimony as Attachment 9 is a sum-mary of the DeLaval inspection history prepared by the NRC's Vendor Inspection Branch. The vendor inspection
. history was discussed by John Collins, Regional Adminis-trator for Region IV of the Nuclear Regulatory Commission, at a January 26, 1984 meeting NRC Staff /DeLaval Owners' Group meeting. Mr. Collins expressed serious reservations about the adequacy of both the DeLaval and utilityk' 'OA/OC program,-as follows:
! As we indicated at the beginning, we have p summarized in these slides the findings.
- But, more that's of interest. If you care- l fully review the findings that were handed j (Footnote cont'd from previous'page) .
to.16, 1981), issued ~ September 18, 1981; 82-01, (January
- 25 to 29, 1982), issued April 15, 1982; 82-02, (August 23 to.26, 1982), issued December 8, 1982; and 83-01, (July 11 to 15,. 1983), issued October 3, 1983.
to you that were documented in the handout . to you, one thing it says to me, in my opinion, is that not only has there been problems at the manufacturing shop, but also, in my opinion, calls into cuestion the adequacy of the vendor programs or surveillance programs that are being conducted by the utilities. Had some of these been identified up front by utilities on-site inspection programs, or receiving inspection programs, or procurement pro-grams, I think they could have been identi-fied even sooner than now. .So, i calls into ouestion your own programs.ll't really/
- (Emphasis added). Similarly, Mr. William Foster of the NRC Staff stated recently that the number and nature of violations and nonconformanceSat
. neLaval indicated to him that the DeLaval OA System was "in e f fe c tive . "3.8,./
0: What is the significance in the context of this proceeding of the NRC's findings concerning DeLaval with respect to LILCO's responsibility. for the diesel failures that have required'it to seek an exemption?
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17/ John Collins. " Transcript of Meeting on DeLaval Diesel Generators," held at the Nuclear Regulatory Commission headquarters, Bethesda, Maryland, January 26, 1984, appended as Attachment 10. 18/ Deposition of William Poster, May 22, 1984, at 16. 24 - 7-.,.- --
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A: LILCO should'have been aware'of the NRC's DeLaval inspection findings since the reports were oublicly available. LILCO should have read these NRC inspection reports and taken appropriate actions. This is especially the case regarding LILCO since the 1974-76 experi-ence (discussed above) had given bases for , concern. We have found little evidence, how-ever, of any systematic response by LILCO man-agement to determine the root cause(s) in the OA/OC program implementation which resulted in the numercus nonconfo rmances found at DeLaval by the NRC. This failure by LILCO further supports our belief that LILCO's need for an exemption is the result of its own inappropriate actions or inaction.11/ 19/ LILCO should also have been alerted to potential problems with the Shoreham diesels as a result of the pat' tern of deficiencies in DeLaval's production of other diesel , engines for nuclear service, which resulted in numerous
, operational problems. These problems were generally reported by DeLaval in Part 21, Title 10 of the Code of Federal Regulations reports, or by the owners of the die-sels in Part 50.55(e), Title 10 of the Code of Federal Regulations reports. Copies of such Part 21 reports were sent to LILCO by DeLaval.
i 0: Is' there any other basis ' for your opinion that LILCO' c need for. an exemption results from' LILCO's own inappropriate actions? A: Yes. DeLaval diesel owners have documented serious operational problems in non-nuclear ap-plications similar to those experienced by nu-clear users. Thus, in addition to the problems LILCO itself experienced with the DeLaval die-sels prior to 1983, if LILCO had looked, it would have found much additional evidence of the unsatisfactory design and manufacture of'DeLaval diesels similar to the Shoreham diesels. In our opinion, in view of the history known to LILCO o f O A. problems with DeLaval, LILCO, prior to (~ , 1983, should have tracked and responded to the significant problems with DeLaval diesels in non-nuclear applications. This is especia11y the case since the lack of operating experience of DeLaval diesels in nuclear applications
, should have led LILCO to inquire how DeLaval l
l- diesels were performing in non-nuclear applica-tions. . i l '. t L. i
For example, the DeLaval diesels supplied for : I the ship M.V. Columbia have experienced many 1 1 conoonent failures including: o Cylinder heads design and manufacturino defects-o Cylinder liner distortion and wear - due to l i block distortion o Piston ring distortion and wear - due to block distortion o Cylinder blocks - distortion and cracking o Connecting rod bearings - design of articu-lated connecting rod assembly o Main bearings - premature wear, high load-ing o Camsha fts - premature wear 20/ Based on the preceding, the authors of the M.V. Columbia evaluation concluded: rM]ajor moving components of the engine failed or required an inordinate amount of corrective maintenance at a significantly higher rate as compared to either DeLaval's recommended scheduled maintenance or other 2n/ Seaworthy Engine Systems Report No. 124-01, Evaluation Of The Operational And Maintenance History Of, And Recent i- Modifications To, The Main Engines In the M.V. Columbia, April, 1983. Other shipboard failures of the same nature experienced by the Pride of Texas are set forth in Attach-ment A to letter from C.C. Wei, Falcon Carriers, Inc. to C. Matthews, DeLaval, Re: Pride of Texas Engine Problems, July 22, 1982. e- -- - * - , m-- ,- .----.,.,.,,,,.,.,_,.,,,..,-g -
, , - , , - , . , ,.,.---,-..,.,.,.,,,...e,
+ typical diesel manufacturer's TBOs. The types of failures and number of failures of some of - the major components indicates !
. design _ deficiencies in these components. l Two critical components which have been subject' to failure, which are'not typically expected to routinely fail, were the artic-ulated connecting rods and cylinder blocks.2J,/
0: Why do,you believe that LILCO's failure to consider non-nuclear data concerning the DeLaval diesels was inap- l i propriate? l A As noted above, the lack of DeLaval diesels in nuclear ap-plications should have led LILCO to inquire regarding their performance in non-nuclear service. Indeed, LILCO itself apparently considered non-nuclear applications of the DeLaval diesels to be relevant to the use of the die-sels at Shoreham. For example, LILCO relied upon DeLaval's allegedly good non-nuclear experience in other aspects of this proceeding. In his affidavit attached to LILCO's Opposition to Suffolk County's Motion to Add an Emergen'cy Diesel Generator Contention, May 16, 1983, Mr. Youngling of LILCO testified: 21/ Seaworthy Engine Systems Report No. 124-01, Evaluation Of The Operational And Maintenance History Of, And Columbia, Recent Modifications To, The Main Engines In the M.V. April, 1983. e
T The vendor has. advised LILCO that the basic diesel engine in the Shoreham diesel gener-ators has been in production since the early 1950's. There are 97 diesel engines in this country thatsare essentially
- ' identicwl _or very similar to the Shoreham d_ie s e l s .
(Emphasis added). Mr. Youngling later testified that: Some of the' diesels that we have cited in our 97 are marine application diesels, others are stationary application for power production and some are nuclear applica-tions.22/ If LILCO had carefully scrutinized available data, how-ever, it would have found actually that very serious , problems were being experienced in non-nuclear DeLaval diesels. In our opinion, a careful and timely look by LILCO at the non-nuclear. experience with DeLaval diesels would have
,' caused LILCO to review the adequacy of the Shoreham die-sels well before their catastrophic failure in 1983. How-ever, there is no evidence prior to 1983 that-LILCO man-agement sought to conduct such reviews, despite the . fact
~
that diesel operation was critical to the startup of 22/
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Transcript of diesel proceeding, June 10, 1983 (" Hearing Transcript"), at 21,291. c_e. ,-,.,-4.r.-.%..- ,..-,,w.,.--..-._ , , . . - - . . , -
r I Shoreham'and despite the evidence, that grew stronger through-the years, and of which LILCO had both direct and indirect knowledge, that DeLaval's diesels were seriously deficient for nuclear application. Q: Does LILCO's purchase of alternate diesel generators, as stated in the Application for Exemption (p. 25), support the requested exemption? At 43. At the October 26, 1983 LILCO Board of Directors meeting, the LILCO Board ratified a contract with the Fairbanks Morne Engine Division of Colt Industries (" Colt") for three 4400 kilowatt diesels for Shoreham et a cost of $12.995 million. However, that action does not change our opinion about the reasons LILCO should not be granted the requested exemption. Long before 1983,-LILCO could, indeed should, have recognized the extremely serious problem with the DeLaval diesels and have perhaps purchased diesels from Colt. Indeed, LILCO could have selected the Colt diesels originally, and thus have avoided altogether the problems with the DeLaval diesels and the need for an exemption. Colt submitted a bid in 1974 for three 4,296 kilowatt units. The Colt bid exceeded the DeLaval proposal by only
$100,967 (i.e., S2,210,967 for the Colt diesels versus
$2,110,000 for the DeLaval diesels), but the Colt offer
.was determined to be technically unacceptable by LILCO be-
-cause the kilowatt rating was deemed larger than recuired.23/ We believe that LILCO was in error in excluding Colt on this basis. Colt's prior experience in sunplying nuclear grade diesels was given insufficient
. weight in LILCO's technical evaluation. In our opinion i-LILCO should have considered whether the QA/QC and other critical processes would have gone as smoothly with DeLaval, a vendor that had no previous nuclear experience, as they might have with Colt, which had extensive experi-ence in qualifying its diesels for nuclear application.
In this sense, perhaps DeLaval was not the lowest quali-fled bidder. Q: What impact have the diesel problems had cx1 the date for
' the operation of Shoreham?
A: LILCO contends that it would have been able',to proceed with low power operation of Shoreham shortly after the 23/ " Technical Evaluation, Diesel Generator Sets - SHI-89," April 5, 1974, attached to letter from J.P. Allen, Stone &
~~
Webster project engineer, to H.C. Buckley, LILCO Purchasing Agent, April 11, 1974.
, ~ ~ . _ . . . - . . - _ . -- ... -. .~ _ . . _ . . - . .
J' 4 t
-l Atonic Safety Licensing _ Board issued ~its Partial Initial i
Decision on' September 21, 1983 had it not been for the h problems. encountered with:the diesels. Therefore, it appears that the- DeLaval d esel problems are respons ble
~
.' i i 4 for the delays from September 21, 1983 until-such time as
-Shoreham'hegins low power operation, and constitute the reason for LILCO's alleged need for an exemption. As 4
notedLpreviously, however, LILCO had ample opportunity priorztc Fall 1993 to take actions to head off the diesels being'in the critical path. LILCO failed.to'take advantage of these numerous opportunities. IV. CONCLUSIONS 0: What are your conclusions concerning . the selection, pro-curement, and installation of Shoreham's diesel genera-tors? A: Our invest'igation of these problems reveals that LILCO,
~
directly or through its; cont'ractor, Stone and Webster, failed to act appropriately to assure.that it acquired and installed- emergency! diesel' generators suited for use at shoreham. J.
o LILCO and Stone and Webster failed to properly or promptly obtain, review, and follow up on available information that demonstrated deficiencies in the DeLaval CA program as well as numerous flaws in the product resulting from that program; o LILCO improperly excluded full consideration of the other: potential diesel generator suppliers, specifi-3 cally the Colt hid, and failed to properly evaluate Colt's nuclear experiencer o LILCO relied too heavily upon-DeLaval to design and manufacture the diesels, and thus failed to assure that DeLaval and Stone and Webster carried out their delegated QA tasks; ! o LILCO failed to conduct a suitable design verifica-5 tion of the DeLaval -diesels at an early date, and i thus failed to detect that the diesels may have sig-nificant deficiencies that prevent their approval for I nuclear application. ! o LILCO failed to adhere to the NRC's OA/OC require-1 ments and thus failed to take the planned and system-atic actions necessary to provide adequate _we~sm
-- ,-o,, -w-,m~-------w~--
l 1/ . confidence that(the diesels vill perform satisfacto-rily in service; and o LILCO failed to initiate prceptly appropriate remedi-al sensures to address the' numerous known i / deficiencies in the Shorehamzdiesels.
< c
.The result of the preceding is that the efforts required -
to remedy the diesels have significantly delayed fuel' load and low power testing at Shoreham. Q: What lLs the significance of your findings with ' regard to J LILCO's Application for Exemption and the proposed Low Power Cperating License? i As LILCO proposes, contrary to regulatica and past practice, that lov' power operation should be permitted without
; benefit of a qualified, on-site supply of emergency AC
' ~
power. LILCO argues that 'this unusual step . should be ( :y E -' taken because of the " good faith" shown by IILCO's
" strenuous efforts to comply with CDC 17."J/ LILCO
'further states that "[ilt is only because of problems arising during preeperational tests-that they (the DeLaval diesels) have not yet been licensed." We disagree L J- I i ___ ____ ;
L ! 3/ May 22, 1984 Application for Exenstion, page 24. ya
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with this position. Rather, it is because of LILCO's insufficient actions since 1974 in the total diesel gener-ator procurement and installation process described above
.that this delay has-occurred. The problems arose far in advance of LILCO's late 1982 preoperational testing pro-gram and with prompt action could have been addressed at a far' esrlier date, thus eliminating any possible need for the exemption' application. Thus, we conclude that the ex-ceptional circumstances claimed by LILCO do not exist, particularly since LILCO itself is largely responsible for the problems which have occurred, and thus no exemption is warranted.
l h-I
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1 b PROFESSIONAL QUALIFICATIONS OF DALE G. BRIDENBAUGH DALE G. BRIDENBAUGH 1723 Hamilton Avenue Suite K. j San Jose, CA 95125 - t(408) 266-2716 EXPERIENCE: 1976 --PRESENT President - MHB Technical Associates, San Jose, California Co-founder and' partner of. technical. consulting firm. Specialists in energy consulting to governmental and other groups interested in evaluation of ! nuclear plant safety and licensing. Consultaat in this capacity to state agencies in California, New York..-Illinois, New Jersey, Pennsylvania, Oklahoma and Minnesota and to the Norwegian Nuclear Power' Committee, Swedish Nuclear. Inspectorate, and various other organizations and environmental groups. Performed extensive safety analysis for Swedish Energy Commission and contributed to the Union of Concerned Scientist's Review of WASH-1400. Consultant to the U.S. NRC - LWR Safety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural
' Resources Defense Council, and contributed to the Department of Energy LWR Safety Improvement Program for Sandia Laboratories. Served as expert-witness in NRC and atate utility commission hearings.
-1976 - (FEBRUARY - AUGUST)
Consultant, Project Survival, Palo Alto, California 'i Volunteer work on Nuclear Safeguards Initiative campaigns in California, Oregon, Washington, Arizona, and Colorado. Numerous. presentations on nuclear power and alternative energy' options to civic, government, and college groups. Also resource person for public service presentations on radio:and television.
' 1973 - 1976
' Manager, Performance Evaluation and' Improvement, General Electric Company -
Nuclear Energy Division, San Jose, California Managed seventeen technical and seven clerical personnel with responsibility,for establishment and management of systems to monitor and 1 4 l 1
-- ,-,..-,-..-,--.---,n,- . . . ~ , -
f. measure Boiling Water Reactor equipment and system operational performance. Integrated General Electric resources-in customer plant modifications,'coordincted correction of causes of forced outages and of efforts to improve reliability and performance of BWR systems. Also responsible for development of Division Master Performance Improvement Plan as well as for numsrous Staff'special assignments on long-range studies. Was on special assignment for the management of two different ad
' hoc projects formed to resolve unique technical problems.
1972 - 1973 Manager, Product Service, General Electric Company - Nuclear Energy Division, San. Jose, California f Managed group of twenty-one technical and four clerical personnel. Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties. Also in charge of refueling and service planning, performance analysis, and service , communication functions supporting all completed commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland). 1968 - 1972 Manager, Product Service, General Electric Company - Nuclear Energy Division, San Jose,-California Managed sixteen technical and six clerical personnel with the responsibility for all customer contact, planning and execution of work required after the customer acceptance of department-suppited plants and/or equipment.- This included quotation, sale and delivery of spare and renewal
, parts. Sales volume of parts increased from $1,000,000 in 1968 to over
- S3,000,000 in 1972.
-1966 - 1968 Manager, Complaint and Warranty Service, General Electric Company - Nuclear Energy Division, San Jose, California Managed group of six persons with the responsibility for customer contacts, planning and execution of work required after customer acceptance of department-supplied plants and/or equipment--both domestic and overseas.
1963 - 1966 Field Engineering Supervisor, General Electric Company, Installation and Service Engineering Department, Los Angeles, California Supervised approximately eight field representatives with responsibility for General Electric steam and gas turbine installation and maintenance
~
work in Southern California, Arizona, and Southern Nevada. During this period was responsible for the installation of eight different central station steam turbine-generator uni'as, plus much maintenance activity. Work included custoner contact, preparatior. of quotations, and contract
' negotiations. -1956 - 1963 .
I Field Engineer, General Electric Company, Installation and Service Engineering Department, Chicago, Illinois l= Supervised installation and maintenance of steam turbines of all sizes. Supervised crews of from ten to more than one hundred men, depending on the job. Worked primarily with_large utilities but had significant-work with steel, petroleum and other process industries. Had four years of
, experience at construction, startup, trouble-shooting and refueling of the i
first large-scale commercial nuclear power unit. 1955 - 1956 Engineering Training Program, General Electric Company, Erie, Pennsylvania, and Schenectady, New York Training assignments in plant facilities design and'in steam turbine
- i. testing at two General Electric factory locations.
1953 - 1955 l United States Army - Ordnance School, Aberdeen, Maryland Instructor - Heavy Artillery Repair. Taught classroom and shop disassembly i of artillery pieces. 1953 Engineering Training Program, General Electric Company, Evendale, Ohio Training assignment with Aircraf t Gas Turbine Department. !' EDUCATION & AFFILIATIONS: BSME - 1953, South Dakota School of Mines and Technology, Rapid City, South Dakota, Upper 1/4 of class. l Professional Nuclear Engineer - California. Certificate No. 0973. Member - American Nuclear Society i l l J l j l l l
b g. 1-Various. Company Training Courses during career. including Professional Business Management, Kepner Tregoe Decision Making, Effective Presentation, Land numerous technical seminars. i EONORS & AWARDS: Sigma Tau - Honorary Engineering Fraternity. l General Managers Award, General Electric Company. , !~
. PERSONAL DATA:
Born November 20, 1931, Miller, South Dakota. Married, three children 6'2", 190 lbs., health - excellent > , Honorable discharge from United States Army Hobbies: Skiing, hiking, work with Boy Scout Groups
- PUBLICATIONS & TESTIMONY:
- 1. Operating and' Maintenance Experience, presented at Twelf th Annual Seminar for Electric Utility Executives, Pebble Beach, California, 0.ctober 1972, published in General Electric NEDC-10697, December 1972.
- 2. Maintenance and In-Service Inspection, presented at IAEA Symposium on-
- _ Experience From Operating and Fueling of Nuclear Power Plants, Bridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.
,. z 3 .' Operating and Maintenance Experience, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, January, 1974. l 4. Improving Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, January,1974.
- 5. Application of Plant Outage Experience to Improve Plant Performance, Bridenbaugh and Burdsall, American Power Conference, Chicago,
[ Illinois, April 14, 1974. E
- 6. Nuclear Valve Testing Cuts Cost, Time, Electrical World, October 15, 1974.
[- l 4
-, . , ,, , r.-- my ,--.w., . . , _ , , - - , , , - .[----,-,mm-,.e.,--,--,m-v-, ,mn.r,--,,,v,. #
i 7 Testimony of,D.-G. Bridenbaugh, R. B. Hubbard, and G. C. Minor before the United States Congress, Joint Committee on Atomic Energy, February 1 18,'1976, Washington, D.C. (Published by the Union of Concerned Scientists, Cambridge, Massachusetts.)
'8. Testimony of D. G. Bridenbaugh, R. B. Hubbard, G. C. Minor to the .
-California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.
'9. Testimony by D. G. Bridenbaugh before the California Energy.
Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency Planning, Avila Beach, California, November 4, 1976.
- 10. Testimony by D. G. Bridenbaugh before the U. S. Nuclear Regulatory Commission, subject: Diablo Canyon Nuclear Plant Performance, Atomic Safety and Licensing Board Hearings, December, 1976,
- 11. Testimony by D. G. Bridenbaugh before the California Energy Commission, subject: Interim Spent Fuel Storage Considerations, March 10, 1977.
- 12. Testimony of D. G. Bridenbaugh before'the New York State Public Service Commission Siting Board Hearings concerning the Jamesport Nuclear Power Station, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April, 1977.
- 13. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject: Decommissioning of Pressurized Water Reactors, Sundesert Nuclear Plant Hearings, June 9, 1977.
a.
- 14. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject: Economic Relationships of Decommissioning, Sundesert Nuclear Plant, for the Natural Resources Defense Council, July 15, 1977.
- 15. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400, Kendall, Hubbard, Minor & Bridenbaugh, et al, for the Union of Concerned Scientists, August, 1977.
- 16. Testimony by D. G. Bridenbaugh before the Vermont State Board of Health, subject: Operation of Vermont Yankee Nuclear Plant and Its Impact on Public Health and Safety, October 6, 1977.
- 17. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board, subject: Deficiencies in Safety Evaluation of Non-Seismic Issues, Lack of a Definitive Finding of Safety, Diablo Canyon Nuclear Units, October 18, 1977 Avila Beach, California.
.- _ ________ _ _._ _ _ _ _ ____J
,3~ , ~
. 18. ' Testimony by D. G.,Bridenbaugh before the Norwegian Commission on Nuclear Power, sub' ject: Reactor Safety / Risk, October 26, 1977.
- 19. Swedish Reactor Safety Study: Barseback Risk Assessment, MHB Technical: Associates, January.-1978. (Published by the Swedish Department of Industry as Document DsI 1978:1)
- 20. ' Testimony by D. 'G Bridenbaugh before the Louisiana State Legislature Committee on Na'thral Resources, subject: Nuclear Power Plant Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.
- 21. Spent Fuel Disposal Costs, report prepared by D. G. Bridenbaugh for the Natural Resources Defense Council (NRDC), August 31, 1978.
- 22. Testimony of D. G. Bridenbaugh, G. C. Minor, and R. B. Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox
- Nuclear Power Station Construction Permit Hearings, September 25, 1978, Tulsa, Oklahoma.
- 23. Tes'timony of D. G. Bridenbaugh and R._B. Hubbard before the Louisiana Public Service Commission, Nuclear Plant and Power Generation-Costs, November 19, 1978, Baton Rouge, Louisiana.
,,24. Testimony by D. G. Bridenbaugh before the City Council and Electric Utility Commission of Austin, Texas.. Design,JConstruce. ion, and
- Operating Experience of Nuclear' Generating Facilities, December 5, 1978, Austin, Texas.
[
- 25. Testimony by D. G. Bridenbaugh-for the Commonwealth of Massachusetts, Department of Public. Utilities, -Impact of Unresolved Safety Issues, Generic Deficiencies, and-Three Mile Island-Initiated Modifications on Power Generation Cost at the Proposed Pilgrim-2 Nuclear Plant, June 8, 1979.
[ 26. Improving the Fafety of LWR Power Plants, NHB Technical Associates, prepared for U.S. Dept. of Energy, Sandia Laboratories, September 28, 1979.
- 27. BWR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), October,1979.
- 28. Uncertainty in Nuclear Risk Assessment Methodology. MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), January 1980.
4 6-a- Wsev- we+w-Ae-----mn < en w,me,-,--- ,s ~ w w an w o--- n w ~ - w ww~e----~n- w-* raw n,ww_
- 29. Testimony of'D. G. Bridenbaugh and G. C. Minor before the' Atomic Safety and Licensing Board, in the matter of Sacramento Municipal.
- Utility. District, Rancho Seco Nuclear Generating Station following TMI-2 accident, subject: Operator Training and Human Factore Engineering, for the California Energy Commission, February 11, 1980.
- 30. Italian Reactor Safety Study: Caorso Risk Assessment, MHB Technical Associates, for Friends of the Earth, Italy, March, 1980.
- 31. Decontamination of Krypton-85 from Three Mile Island Nuclear Plant, H. Kendall, R. Pollard, & D. G..Bridenbaugh, et al, The Union of Concerned Scientists, delivered to the Governor of Pennsylvania, May 15,.1980.
' .32. Testimony by D. G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, August, 1980.
33... Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, for Minnesota Pollution Control Agency, September, 1980.
- 34. Position Statement, Proposed Rulemaking on the Storage and Disposal of 7 Nuclear Waste, Joint Cross-Statement of Position of the New England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980.
- 35. Testimony by D. G. Bridenbaugh and G. C. Minor, before the New York State Public Service Commission, In the Matter of Long Island Lighting Ccmpany Temporary Rate Case, prepared for the Shoreham Opponents-
, Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.
- 36. -Supplemental Testimony by D. G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Department of the Public' Advocate, Division of Rate Counsel, Analysis of 1979 Salem-1 Refu(ling Outage, December, 1980.
- 37. Testimony by D. G. Dridenbaugh and G. C. Minor, before the Naw Jersey Board of Public Utilities,~on behalf of New Jersey Department of the a Public Advocate, Division of Rate Counael, Oyster Creek 1980 Refueling Outage Investigation, February 1981.
- 38. Economic Assessment: Ownership Interest in Palo Verde Nuclear l
r Station, MHB Technical Associates, for the City of Riverside, September l'. 1981. f
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F
- 39. Testimony of D. G. Bridenbaugh before the Public Utilities Commission of-Ohio, in the Matter of the Regulation of the Electric Fuel Component Contained Within the . Rate. Schedules of the Toledo Edison Company-and Related Matters, subject
- _ Davis-Besse Nuclear Power ,
, -Station 1980-81 Outage Review, November, 1981. 40? Supplemental Testimony of D. G. Bridenbaugh before the Public < Utilities Commission of' Ohio, in the matterLof the Regulation of the f Electric Fuel. Component Contained within the Rate Schedules of the Toledo Edison Company and Related Matters, subject: Davis-Besse
' Nuclear Power Station 1980-81 Outage Review, November 1981..
e
- 41. = Systems Interaction and Single Failure Criterion, Phase 2 Report, MHB l . Technical Associates for the Swedish Nuclear Power Inspectorate (SKI),
-January, 1982.
- 42. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Governor iEdmund G. Brown.Jr., before the Atomic Safety and Licensing Board, regarding Contention 10, Pressurizer Heaters, January 11, 1982.
- 43. Testimony of D. G. Bridenbaugh-and G. C. Minor on behalf of Governor
! Edmund G. Brown Jr., before the Atomic Safety and Licensing Board, l~ regarding Contention'12, Block and Pilot Operated Relief Valves, January 11, 1982.
- 44. Testimony of D. G. Bridenbaugh before the Commonwealth of Massachusetts, Department of Public' Utilities, on behalf of the >
I Massachusetts Attorney General, Pilgrim Nuclear Power Station, 1981-82 Outege Investigation, March 11, 1982. i - ' 45. Tesrimony of D. G. Bridenbaugh before the Pennsylvania Public Utility Conesission, on behalf of the Pennsylvania Of fice of Consumer Advocate,
~ Beaver Valley Outage, March, 1982.
L 46'. Interim testimony of D. G. Bridenbaugh before the Illinois Commerce Consnission, on behalf of the Illinois Attorney General's Office, Expected Lifetimes and Performance of Nuclear Power Plants, March, 1982. L 47. .Testitaony of D. G. Bridenbaugh and G. C. Minor before the Atomic l Safety and Licensing Board, on behalf of Suffolk County, in the matter of Long Island Lighting Company, Shorehma Nuclear Power Station, Unit }, 1, regarding Suffolk County Contention 11, Passive Mechanical Valve l Failures, April 13, 1982.
- 48. Testimony of D. G. Bridenbaugh and R. B. Hubbard, in the Matter of Jersey Central Power and Light Company For an Increase in Rates for Electrical Service, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Three Mile Island Units 1 &
2, Cleanup and Modification Programs, May, 1982.
~ . . _ . ~ . _ .. _ _ .._._-_.. _ . _ _ . _ _ _ _ _ _ _ _._._.. _ , _ -- _ . _ .. _ - ~ ,.
- 49. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1,
.regarding Suffolk County Contention 22, SRV Test Program, May 25, 1982.
- 50. - Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of
-long Island Lighting Company, Shorenam Nuclear Power Station, Unit 1, regarding Suffolk County Contention 28(a)(vi) and SOC Contention l- 4 7A(6), Reduction of SRV Challenges, June 14, 1982.
l L 51. Testimony of D. G. Bridenbaugh before the Illinois Commerce L Commission, on-behalf of the Illinois Attorney General's Office, Expected Lifetimes and Performance of Nuclear Power Plants, June 18, 1982.
- 32. Testimony of 0. G. Bridenbaugh and R. B. Hubbard on behalf of the Ohio Consumers Counsel, before the Public Utilities Commission of Ohio, regarding Construction of Perry Nuclear Generating Unit No. 1, October'
- 7, 1982.
- 53. Issues Affecting the Viabiling and Acceptability of Nuclear Power Usage in the United States, prepared by MHB Technical Associates for l Congress of the United States, Office of Technology Assessment for use i
in conjunction with Workshop on Technological and Regulatory Changea in Nuclear Power, December 8 & 9, 1982. l 54 Testimony of D. G. Bridenbaugh on behalf of Rockford League of Women Voters, before the Atomic Safety and Licensing Board, in the matter of I Commonwealth Edison Company, Byron Station, Units .1 and 2, regarding ' Contention 22, Steam Generators, March 1, 1983.
- 55. Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Office of Consumer
! Advocate, Regarding the Cost of Ccnstructing the Susquehanna Steam Electric Station, Unit I, Re: Pennsylvania Power and Light, March 18, 1983.
- 56. Surrebuttal Testimony of D. G. Bridenbaugh before the Pennsylvania i
Public Utility Commission, on behalf of the Office of Consumer
-Advocate, Regarding the Cost of Constructing the Susquehanna Steam Electric Station, Unit I, Re: Pennsylvania Power and Light, April 20, 1983. ,
l 57. Testimony of D. C. Bridenbaugh In the Matter of Public Service Gas & i Electric, Base Rate Case, Nuclear Construction Expenditures, on behalf
- of New Jersey Department of the Public Advocate, Division of Rate l
Counsel, October 13, 1983 l i
- l
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d 1
- 58. Affidavit of D. G. Bridenbaugh, in the Matter of Jersey Central Power and Light, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, TMI Fault Investigation, November 23, 1983.
- 59. Testimony of D. G. Bridenbaugh, in the Matter of Public Service Electric & Gas, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, LEAC Investigation. Salea-I outages, December 1, 1983.
- 60. Rebuttal Testimony of D. G. Bridenbaugh, in the Matter of public Service Electric & Gas, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, LEAC Investigation, Salem-1 Outages, January 18, 1984 l.
l- 61. - Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G. C. Minor before the State of New York Public Service Commission, PSC l Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investigate the Cost of the Shoreham Nuclear Generating l Facility - Phase II, on behalf of County of Suffolk, February 10, 1984
- 62. Status Report, WJ Zimmer Plant. Assessment of Options, MHB Technical Associates, prepared for The Ohio Office of the Consumer's Counsel, February 23, 1984.
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b O ATTACHf!ENT 2 .
PROFESSIONAL QUALIFICATIONS OF RICHARD B. HUBBARD RICHARD B. HUBBARD MHB Technical Associates 1723 Hamilton Avenue Suite K. San Jose,' California 95125 EXPERIENCE:
'9/76 - PRESENT Vice-President - MHB Technical Associates, San Jose, California.
Founder, and Vice-President of technical consulting firm. Specialists in independent energy assessments for government agencies, particularly - technical and economic evaluation of nuclear power facilities. Consultant in this capacity to California, Massachusetts, Oklahoma and Illinois Attorney Generals, Minnesota Pollution Control Agency, German Ministry for Research and Technology, Governor of California, Swedish Energy' Commission, Swedish Nuclear Inspectorate, Suffolk County, Ohio Consumer's Counsel, New Jersey Public Advocate, and the U. S. Department of Energy. Also provided studies and testimony for various public interest groups including the Center for Law in the Public Interest, Los Angeles; Public Law Utility Group, Baton Rouge, Louisiana; Friends of the Earth (F0E),' Italy; and the
, Union of Concerned Scientists, Cambridge, Massachusetts. Provided
- testimony to the U.S. Senate / House Joint Committee on Atomic Energy, the
~
U.S. House Committee on Interior and Insular Affairs, the California Assembly, Land Use, and Energy Committee, the Advisory Committee on Reactor Safeguards, and the Atomic Safety and Licensing Board. Performed comprehensive risk analysis of the accident probabilities and consequences at the Barseback Nuclear Plant for the Swedish Energy Commission and , edited, as well as contributed to, the Union of Concerned Scientist's . technical review of the NRC's Reactor Safety Study (WASH-1400). I 2/76 - 9/76 l l Consultant, Project Survival, Palo Alto, California. Volunteer work on Nuclear Safeguards Initiative caepaigns in California, Oregon, Washington,. Arizona, and Colorado. Numerous presentations on , ., nuclear power and alternative energy options to civic, government, and college groups. Also resource person for public service presentations on radio and television. I
... . - - - .- - . -. -. - . --- -~ . .5/ 75 - 1 /76 4
Manager - Quality Assurance Section, Nuclear Energy Control and Instrumentation Department, General Electric Company, San Jose, California. Report to the Department General Manager. Develop and implement quality plans, programs, methods, and equipment which assure that products produced by the Department meet quality requirements as defined in NRC regulation 10 CFR 50, Appendix B, ASME Boiler and Pressure Vessel Code, customer contracts, and GE Corporate policies and procedures. Product areas include radiation sensors, reactor vessel internals, fuel handling and servicing tools, nuclear plant control and protection instrumentation systems, and nuclear steam supply and Balance of Plant control room panels. Responsible for approximately 45 exempt personnel, 22 non-exempt personnel, and 129 hourly personnel with an expense budget of nearly 4 million dollars and equipment investment budget of approximately 1.2 million dollars. 11/71 - 5/75 Manager - Quality Assurance Subsection, Manufacturing Section of Atomic Power Equipment Department, General Electric Company, San Jose, California. Report to the Manager of Manufacturing. Same functional and product responsibilities as in Engagement #1, except at a-lower organizational report level. Developed a quality system which received NRC certification in 1975. The system was also successfully surveyed for ASME "N" and "NPT" symbol authorization in 1972 and 1975, plus ASME "U" and "S" symbol
. authorizations in 1975. Responsible for from 23 to 39 exempt personnel, 7 to 14 non-exempt. personnel, and 53 to 97 hourly personnel.
3/70 - 11/71
. Manager - Application Engineering Subsection, Nuclear Instrumentation Department, General Electric Company, San Jose, California.
Responsible for the post order technical interface with architect engineers and power plant owners to define and schedule the instrumentation and control systems for the Nuclear Steam Supply and Balance of Plant portion of nuclear power generating stations. Responsibilities included preparation of the plant instrument list with approximate location, review of interface drawings to define functional design requirements, 'and release of functional requirements for detailed equipment designs. Personnel supervised included 17 engineers and 5 non-exempt personnel. 12/69 - 3/70 Chairman - ?quipment Room Task Force, Nuclear Instrumentation Department, General Ele.tric Company, San Jose, California. Responsibli'for a special task force reporting to the Department General Manager to define methods to improve the quality and reduce the
installation time and cost of nuclear. power plant control rooms. Study resulted in the conception of a factory-fabricated control room consisting of signal conditioning and operator control panels mounted on modular floor sections which are completely assembled in the factory and thoroughly tested for proper operation of interacting devices. Personnel supervised
. included 10 exempt personnel.
12/65 - 12/69. i Manager - Proposal Engineering' Subsection, Nuclear Instrumentation Department. General Electric Company, San Jose, California. l Responsible for the application of instrumentation systems for nuclear power reactors during the proposal and pre-order period. Responsible for technical review of bid specifications, preparation of technical bid clarifications and exceptions, definition of material list for cost estimating, and the "as sold" review of contracts prior to turnover to Application Engineering. Personnel supervised varied from 2 to 9 p engineers. + 8/64 - 12/65
; Sales Engineer, Nuclear Electronics Business Section of Atomic Power Equipment Department, General Electric Company, San Jose, California.
. Responsible for the bid review, contract negotation, and sale of instrumentation systems and components for nuclear power plants, test reactors, and radiation hot cells. Also responsible.for industrial sales i: of radiation sensing systems for measurement of chemical properties, level, and density.
I l 10/61 - 8/64-l l- Application Engineer, Low Voltage Switchgear Department, General Electric i Company, Philadelphia, Pennsylvania Responsible for the application and design of advanced diode and i silicon-controlled rectifier (SCR) constant voltage DC power systems and . variable voltage DC power systems for industrial applications. Designed, followed manufacturing and personally tested an advanced SCR power supply for product introduction at the Iron and Steel Show. Project Engineer for a DC power system for an aluminum pot line provided to Anaconda beginning at the 161KV switchyard and encompassing all the equipment to convert the power to 700 volts DC at 160,000 amperes. [ 9/60 - 10/61 i GE Rotational Training Program Four 3-month assignments on the GE Rotational Training Program for college l technical gradt.ates as follows: I c. i
- a. Installation and Service Eng. - Detroit, Michigan Installation and startup testing of the world's largest automated hot strip steel mill.
- b. Tester - Industry Control - Roanoke, Virginia Factory testing of control panels for control of steel, paper, pulp, p and utility mills and power plants. -
' Engineer - Light Military Electronics - Johnson City, New York c. t' Design of ground support equipment for testing the auto pilots on the j F-105.- l l '~
- d. Sales Engineer - Morrison, Illinois
- Sales of appliance controls inciuding range timers and refrigerator cold' controls, f
- EDUCATION
.3achelor of Science Electrical Engineering, University of Arizona, 1960.
Master of Business Administration, University of Santa Clara, 1969. PROFESSIONAL AFFILIATION: Registered Quality Engineer, License No. QU805, State of California. Member of Subcommittee 8 of the Nuclear Power Engineering Committee of the i IEEE Power Engineering Society responsible for the preparation and revision of the following national Q.A. Standards:
- a. IEEE 498 (ANSI N45.2.16): Requirements for the Calibration and ,
Control of Measuring and Test Equipment used in the. Construction and ! Maintenance of Nuclear Power Generating Stations.
- b. IEEE 336 (ANSI N45.2.4): Installation, Inspection, and Testing Requirements for Class lE Instrumentation and Electric Equipment at
- Nuclear Power Generating Stations.
[ c. IEEE 467 : Quality Assurance Program Requirements for the ! Design and Manufacture of Class IE Instrumentation and Electric l Equipment for Nuclear Power Generating Stations. l I am currently a member of the IEEE Committee which is preparing a standard relating to the selection and utilization of' replacement' parts for Class lE equipment during the construction and operation phase. i t i e
- i. l
' PUBLICATIONS AND TESTIMONY:
- 1. In-Core System Provides Continuous Flux Map of Reactor Cores, R. B.
Hubbard and C. E. Foreman, Power, November, 1967.
- 2. Quality Assurance: Providing It, Proving It, R. B. Hubbard, Power, May, 1972.
- 3. Testimony of R. B. Hubbard, D. G. Bridenbaugh, and G. C. Minor before the United States' Congress, Joint Committee on Automic Energy, February 18, 1976, Washington, D.C. (Published by the Union of Concerned Scientists, Cambridge, Massachusetts.) Excerpts from testimony published in Quote Without Comment, Chestech, May, 1976.
- 4. Testimony of R. B. Hubbard, D. C. Bridenbaugh, and G. C. Minor to the California State Assembly Committee on Resources, Land Use, and Energy, Sacramento, California, March 8, 1976.
- 5. Testimony of R. B. Hubbard and G. C. Miaor before California State Senate Committee en Public Utilities, Transit, and Energy, Sacramento, California, March 23, 1976.
- 6. Testimony of R. B. Hubbard and C. C. Minor, Judicial Hearings Regarding Crafenrheinfeld Nuclear Plant, March 16 & 17, 1977, Wurzburg, Germany.
- 7. Testimony of R. B. Hubbard to United States House of Representatives, Subcommittee on Energy and the Environment, June 30, 1977, Washington, D.C., entitled, Effectiveness of NRC Regulations - Modifications to Diablo Canyon Nuclear Units.
- 8. Testimony of R. B. Hubbard to the Advisory Committee on Reactor Safeguards, August 12, 1977, Washington, D.C., Risk Uncertainty Due to Deficiencies in Diablo Canyon Quality Assurance Program and Failure to Implement Current NRC Practices.
- 9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400, Kendall, et. al., edited by R. B. Hubbard and I G. C. Minor for the Union of Concerned Scientists, August, 1977.
- 10. Swedish Reactor Safety Study: Barseback Risk Assessmene, MHB Technical Associates, January 1978 (Published by Swedish Dcpartment of Industry sg Document DSI (1978:1).
- 11. Testimony of R. B. Hubbard before the Energy Facility Siting Counsil, j March 31, 1978, in the matter of Pebble Springs Nuclear Power Plant, Risk Assessment: Pebble Springs Nuclear Plant, Portland, Oregon.
l
-S-
- 12. Presentation by R. B. Hubbard before the Federal Ministry for Research and Technology (BMFT), August 31 and September 1, 1978, Meeting on Reactor Safety Research, Risk Analysis. Bonn, Germany.
- 13. Testimony by R. B. Hubbard, D. G. Bridenbaugh, and G. C. Minor before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of the Black. Fox Nuclear Power Station Construction Permit hearings, Tulsa, Oklahoma.
- 14. Testimony of R. B. Hubbard before the Atomic Safety and Licensing Board, November 17, 1978, in the matter of Diablo Canyon Nuclear Power Plant Operating License Hearings, Operating Basis Earthquake and Seismic Reanalysis of Structures, Systems, and Components, Avila Beach, California.
- 15. Testimony of R. B. Hubbard and D. G. Bridenbaugh before the Louisiana Public Service Commission, November 19, 1978, Nuclear Plant and Power Generation Costs, Baton Rouge, Louisiana.
- 16. Testimony of R. B. Hubbard before the California Legislature, Subcommittee on Energy, Los Angeles, April 12, 1979.
- 17. Testinony of R. B. Hubbard and G. C. Minor before the Federal Trade Commission, on behalf of the Union of Concerned Scientists, Standards and Certification Proposed Rule 16 CFR Part 457, May 18, 1979.
- 18. ALO-62, Improving the Safety of LWR Power Plants, NHB Technical.
Associates, prepared for U.S. Department of Energy, Sandia National Laboratories, September, 1979, available from NTIS.
- 19. Testimony by R. B. Hubbard before the Arizona State Legislature, Special Interim House Committee on Atomic Energy, Overview of Nuclear i
Safety. Phoenix, AZ, September 20, 1979.
- 20. "The Role of the Technical Consultant", Practising Law Institute program on " Nuclear Litigation", New York City and Chicago, November, 1979. Available from PLI, New York City.
- 21. Uncertainty in Nuclear Risk Assessment Methodology, MHB Technical i Associates, March, 1980, prepared for and available from Swedish j Nuclear Power Inspectorate, Stockholm, Sweden.
- 22. Italian Reactor Safety Study: Caorso Risk Assessment, MHB Technical Associates, March, 1980, prepared for and available from Friends of 1
the Earth, Rome, Italy.
- 23. Development of Study Plans: Safety Assessment of Monticello and Prairie Island Nuclear Stations, NHB Technical Associates, August, 1980, prepared for and available from the Minnesota' Pollution Control Agency.
-24. Affidavit of Richard B. Hubbard and Gregory C. Minor before the Illinois Commerce Commission, In the Matter of an Investigation of the Plant Construction Program of the Commonwealth Edison Company, prepared for the League of Women Voters of Rockford, Illinois, November 12, 1980, ICC Case No. 78-0646.
- 25. Systems Interaction and Gingle Failure Criterion, NHB Technical Associates, January, 1981, prepared for and available'from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
- 26. Summary of Emergency Response Planning Criteria for Regional and Local Authorities Near Nuclear Electric Generating Stations, NHB Technical Associates, June, 1981, prepared for and available from Friends of the Earth, Rome, Italy.
- 27. Economic Assessment: Ownership Interest In Palo Verde Nuclear Station, September 11, 1981, prepared for and available from the City of Riverside, California.
28.. Systems Interaction and Single Failure Criterion: Phase II report,. MHB Technical Associates,- December,1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
- 29. z Testimony of Richard Hubbard and Gregory Minor on Emergency Response Planning, Diablo Canyon Operating License hearings before ASLB, January 11, 1982. .
- 30. - Statement of Richard Hubbard before the U.S. House Subcommittee on Energy and Environment concerning QA program breakdowns, November 19, 1981.
- 31. Testimony of Richard Hubbard on Quality Assurance, South Texas ,
Operating License hearing before ASLB, prefiled June, 1981.
- 32. Presentation of Richard Hubbard for Governor Edmund G. Brown, Jr.
concerning PG&E's Proposed Seismic Design Reverification Program, Diablo Canyon Nuclear Power Plant, February 1982.
- 33. Testimony of R. B. Hubbard, G. C. Minor, M. V Goldsmith, S. J.
Harwood on behalf of Suffolk County, before ti.e Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nucles.r Power Station, Unit 1,.regarding Contention 7B, Safety Classification and Systems Interaction, April 13, 1982. , I
)
l k 34 . Testimony of R. B. Hubbard and D. G. Bridenbaugh, in the matter of
-Jersey. Central Power and Light Company For an Increase in Rates for Electrical Service, on-behalf of New Jersey Department of the Public i
Advocate, Division of Rate Counsel, Three Mile Island Units 1 & 2,
- Cleanup and Modification Programs, May, 1982._
- 35. Testimony of R. B. Hubbard and G. C. Minor on behalf of Suffolk 1
County,:before the Atomic Safety and Licensing Board, in the matter of Long, Island Lighting Company, Shoreham Nuclear Power Station, Unit 1 j regarding Suffolk County Contention 27 and SOC Contention 3,
- . Post-Accident Monitoring, May 25, 1982.
; 36. Presentation of R. B. Hubbard for Governor Edmund G. Brown, Jr.
i concerning Diablo Canyon Revstification Program, Diablo Canyon Nuclear Power Plant, September, 1982.
- 37. Testimony of R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and Licensing Board,_in the matter of Long Island
"~ ~ Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contentions 12, 13, 14, and 15, Quality Assurance / Quality Control, June 29, 1982.
- 38. Presentation of Richard B. Hubbard on Behalf of the State of b . California, Before the NRC Commissioners, Proposed Phase II Diablo j Canyon Reverification Program (IDVP), November 10, 1982.
- I 39. Testimony of R. B. Hubbard and Dr. Francisco J. Samaaiego on behalf of Suffolk County, Before the Atomic Safety and Licensing Board,-in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Torrey Pines TechnJ1ogy's Inspection of
- Shoreham Nuclear Power Station, December 21, 1982.
- 40. Supplemental testimony of G. C. Minor, R. R. Hubbard, and M. W.
Goldsmith on behalf of Suffolk County, before the Atomic Safety and , Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding suffolk County I Contention 75, Safety Classification and Systems Interaction, March 23, 1983. 41., Supplemental Affidavit of R. B. Hubbard before the Atomic Safety and Licensing Appeal-Board Concerning Breakdowns in the Diablo Canyon Quality Assurance Program, March 29, 1983. J-
- 42. Declaration of R. B. Hubbard before the Atomic Safety and Licensing 4
Appeal Board, Concerning Breakdowns in Construction Quality Assurance j at Diablo Canyon, May 6, 1983. 1 1 f-
; 4
- 43. Presentation by R. B. Hubbard on behalf of Suffolk County to Cuomo Commission regarding Quality Assurance / Quality Control (QA/QC).
- 44. Testimony of R. B. Hubbard on Behalf of the State of California, Before the Atomic Safety and Licensing Appeal Board, in the matter of Pacific Gas and Electric Co., Regarding Design Quality Assurance, October, 1983.
- 45. Testimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard and G. C.
Minor before the State of New York Public Service Commission, PSC Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investigate the Cost of the Shoreham Nuclear Generating Facility -- Phase . II, on behalf of County of Suffolk, February 10, 1984.
- 46. Status Report. WJ Einmer Plant. Assessment of Options, MEB Technical Associates, prepared for The Ohio Office of the Consumer's Counsel, February 23, 1984 e
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[ January 15, 1981 1 J.E. Taylor f Energency Diesel Generator 102 Problems Encountered To Date l Shoreham Nuclear Power Station - Unit No. 1 W.O. 44430/48923 i The attached report, prepared by T. Brown, J. Higgins and
- W4 Cook accurately state the problems we have had to date.
l An attempt to resolve many of the items was tried on December 18, 1980 when startup arranged a meeting between ourselves,
. S&W and Delaval. Regretfully, Delaval could not attend and no real progress on nroblem solutions were made. ,
4 Another meeting is scheduled for January 20, 1981 at Shoreham and. hopefully resolution to many problems .will be achieved. Many of the problems encountered by Startup to date have been c the result of the " Skid Mounted Equipment", as with this type, the construction organization has very minimal involvement other I than " hooking up" to it. Along these lines, alignment deficiencies ' have been identified, storage problems have been corrected etc., all of which adds to startup's scope of work as related to placing , the equipment into service. I A rescheduling effort of the Diesel generators must be conducted due to the recent Proposed Site pclicy to primars.ly support the Integrated Flush. At the present time, we can not project a ( ' j i preon start date due to many unresolved problems and no projected turnover date for Engines 101 and 103. , l - i . i
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! D.D. Ter C/C y l up Engineer par l
Lead Sta l DDTabc cc T. Brown J. Higgins W. Cook L.W. Lewin W.M. Matejek SR2-R43.010 l i i
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PROBLEM REPORT i R43- EMERGENCY DIESEL GENERATORS
- 1- Procedure that had been JTG approved for subsystem flushes I were not adequate. Specifically, the lube oil flush did c .
not provide sufficient flow to clean the systest. (this l test procedure used B&A pump (40GPM.) which has a normal flow of about 250GPM. Also, the JW system flush procedure uses the J.W. heater circulating pump (50GPM) for a sys-i tem with a normal flow of 800 GPM. This procedure will be revised to incorporate a temporary flush pump. 4 Excessive amounts of time were required to review component f' 2-i lists since (a) initial list missed many items (b) isome-i tries are continually changing resulting in added and/or deleted' sections, and (c) hanger listings change as isos t are revised and the designation changes (E&DCR F 29376) . Changes in component lists are no longer to be reviewed - l
$ only marked noted by test engineer.
s Excessive amounts o'f time was required to review punchlist e 3- , items. This was compounded by (s) reorganization of list.s j by renumbering all items, (b) excessive number of items, (c) failure to perform verification of completion by turnover and (d) non-informative responsiblity assignment. i l.-.._ -~_._..._.,_m _ _ _ . - _ _ . - . _ _ __
J I . 1 mesponsibility is not discussed with the individual resulting frequently in the wrong discipline being assigned, the individual being unaware of his responsi-bility, and the wrong completion code being assigned. 4 The issuing of the complete list each month instead of a list of changes results in an impossible review ll task. ll 4- Excessive amounts of time are required for review of preliminaries. New preliminary release packages are l submitted for review with little or no change in the ! punchlists. Meetings are called to discuss package l updates with the only change being requests for further concessions on number of items required for turnover. t R43A has had six preliminaries and the punchlist is still some 46 pages long. 5- 'construiiti' tin"itathis f6 del'dise#was" poor A e Seceived M l a minimum of requested storage history information. Final engine alignment was not perfomed. There was no record of foundation bolt torquing. Magger readings l t i of generator stator were not up to date. Megger reading 1 4 of generator field and bearing pillow block were non-existant. l f ' 1 1 1
. . . . = . .- -
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- I 6-Ehaserous'decIgn_ana cdnetruction w. ; -.
errors necessitated ini-tiation of EsDCR's ( 65 to date.; This,.has resulted in an exorbitant amount of time being expended reviewing drawings and documents. Many ., of the original problem solutions were incorrect which resulted in rewriting tha E&DCP,or calling SZO to request the naxt issue. We have attempted g get the drawings updated to reflect the system as,it vag designed and to get the drawings that the diese.ls were. built to, but usually we are requested to mark ,up, prints reflecting as built conditions. Problem soligjdens are at a standstill at present, only one has 1:een .answex_e4 s since the end of 1 October - nineteen are unanswered. 7- Numerous repair-reworks (,38) have.been written because
- ---7 of many incomplete or_4sfact%veritems.,~~some of these are a result of EsDCn's,some are a { % . f. Poor factory .
assembly' practices, some are a ' result of a forced turnover with incomplete / deficient components, and some are a re-ruit of poor censtruction pract4ces. A great amount of I time was expended in obtaining,documentations acr. reword _
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oCfactory-wiring. This has also been expended on attempts l to expedite parts and tools for reworks. ) I s
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' s- Extra time has bean expended because of numerous techni-cian changes with no overlap. This has resulted in
' same rework, additional time locacing equipment, and additional time locating documents. 9- Many hours have been expended attempting to est informa-
- tion fer C&Io work (especially the tach-relay, the fuel I oi3 Booster Pump D.C. motor loss of field relay}with 8.ncomplete results. Many hours have been expended i attempting to set up for testing D.C. Circuit breakers i
since there is no regulated DC power supply of 30 amp capacity on site. 10- Pior... storage conditions and wdii;afea_conypal uti consqc1:fonTp1Yase,s had to be courpensated by cleaning of the 102 generator by Startup support. i 11- Poor design of panel cable support and poor housekeeping during construction resulted in a prolonged cleaning i effort to achieve error free operation of relays. 12- original schedules did not allow time for rewritting procedures, reperforming C&Io work because of design i changes, performing design and construction review. 13- original C&Io schedule by previous test engineer allowed ; six weeks. A recalculation including all equipment with j the same allowed tire for devices, indicates that fifteen l weeks should be allowed. I
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x . Modification of diesel generators to upgrade design 14-are being inecrporated. This was not allowed for this in the assigned schedule. , 15- Ad;11tional time and manpcwer was required to clean crank cases of diesel since presexvative of wrong type was sus-pected to have been use& on engine during storage. 16- Additional Test Engineer time was expended clearing construction red tags after system release. 17- Failure to be able to control access to the Diesel room because construction activities were in progress slowed Startcp activities. Construction work on rewiring MCC, l i ! installing scaffolds (for X60 actuators, service water line walk, and conduit resupport), and reworks assigned to construction. Temporary doors were unlocked, knocked f down and holes were cut in them. 18- Power feed (120VAC) Repair / Rework (R35-6) prevented com-plate testing of accessories. l 19- ASME piping was not turned over at original "D" release. There has been confusion in this area concerning who owns which components. We are still unable to use Startup Support to break flanges on there systems - this results in poor control of activities by Startup. 1 l . i ~ _ _ . - - - . __ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ . . _ _ _ _ _ _ _ _
~
i . 20- Lack of personnel continuity has impacted progress - three turnover engineers have been responsible for R43 l since May 1980. 21- Many hours have been spent listing problems with design, drawings, construction, and documentation. Many hours
- have been spent attending meetings - the only result thus far has been requests for more pape: work, (lists a copies of specific E&DCR's) and more meetings. We need to have the diesel generators placed on a higher priority if we are to meet a date required to support other plant activities.
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l Many E5DCRs have been wri::en fer :he R43 Systa=, diesel genera: ors, . vi:n =:s: ef these IEDCRs .being initiated by LILCO Start-Up. The diesel genera::r spe:ificatien SE1-089 is =ainly a perfor=ance specifica-icn, i.e.-design ou:pu: para =e:ers, vi h detailed design
- f :he sys:e= :o be supplied by DeLaval. The spe:ification, however,
[ does reccire :er:si: spe:1fic de: ails such as alar =: and shutdow: ini:ia:1:n . s i;nals. K1:h a parier=ar.:e specift:2:icn as a basis S&W , i
=us: rely en :he manufa :urer's ability Cens::::: to provide a design tha:
l ' a::o=p'_ishes the desired perfor=ance. ion for:es have co=- - l
;;e:ed :he 101 diesel; hewever, Star:-ce is enecun:aring er ble=s 4
a =ajeri:7 ef which are detai'_s re:uired to che:k cu- instru=ents and j subsys:e=s be:ause the ins:alia:1:n and =ain:enance manual furnished j
'y DeLaval doesn': provide enough infor= :1en on se: points and design j para =e:ars :o check various ins:ru=en:a:1on. ,
c j l There are 21so cases where additional details en S&W drawings would ~ ! have hel;2d to eliminate cons:ru:: ion and s:ar:-up pro:le=s. i S:ar:-up is also reviewing :hings in general vi:h a different perspective, tha: ; so=e:i=es rtviewing the maintainability :o a =uch greater exten: , saw.has. i ' 3 In locking each through some of the IIDCRs we see many reques:s for j' :he appropria:e vehicle for i additional infor=acion, se=sti=er nota =eans by whi:h a do: =ented answer ,, requesting the ini:r=a: ion. bu: is r,equired. i =a::h the equip =en: I There are cases where vend::s' drawings did no: and S&W drawings. ! thus resul:in- in incensis:en:les be:vhen vend:: Inspe::1:n could have unc:vered this. We de to an:i:1pa:e si=ils: ;;:ble=s vi:h se:uri:y, except probably vi:h Viconics. ,
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(s,r... . ,. . Energy Consu tents, no.
' 121 SEVENTH = i e i
- PITTSER AGH.F%.15222-3487
- 412/434-EE .
JAK-ENG-83-181 ~ July 12. 1983 . 4 Mr. E. B. McCabe U. S. N.aclear Regulatory Commission 631 Park Avenue Eing of Prussia. PA 19406 ,
SUBJECT:
WITNESS AND EVALUATION OF EMERGENCT DIESEL GENERATOR TESTING AT SHORERAM NUCLEAR POWER STATION FOR NUCLEAR REGULATORY COMMISSION, REGION I STAFF.. FINAL REPORT OF NRC CONTRACT MO. 05-82-249 PARAMETER PURCHASE ORDER NG. NRC-IE-82/83. TASK 38
Dear.Mr. McCabe:
Enclosed are five (5) copies of the final report of the Evaluatich and Witnessing of Emergency Diesel Generator Testing Problems at Shoreham Nuclear Power Station which was performed at Shoreham. New York by Mr. Gailard runkle aad the Energy Consultants. Inc. staff in accordance with . the reference contract. The final report incorporates the NRC consents on the pre 14=4=ry report provided to Mr. G. Eunkle at the meeting in Region I on June 29, 1983. The prelim 1= ry report was submitted to you previously by JAK-ENG-83-161 dated June 17. 1983. If you should have'any questicus or comments, please contact an. 3 Sincerely. ENERGT CONSULTANTS. INC. f
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John A. ye Manager . Design and Consulting
- Engineering Department LTA/cv Enclosures cc: Jim Higgins - U. S. Nuclear Regulatory Commission Richard A. Lofy - Parameter Incorporated e
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% % tR.C FINAL REPORT TO U. S. NUCLEAR REGULATORY COMMISSION REGION I FOR TEST REVIEW, DATA ANALYSIS AND REVIEW OF di.ERGENCY DIESEL GENERATOR OPERATIONAL /RELIAEILITY PROBLEMS AT SHOREHAM NUCLEAR POWER STATION, UNIT I, SHOREHAM, NEW YORK NRC CONTRACT NO. 05-82-249 PARAMETER CONTRACT NO. NRC-IE-82/83, TASK 38 FROM APRIL 25, 1983 TO MAY 19, 1983 PRESENTED ON JULY 12, 1983 cY DESIGN AND CONSULTING ENGINEERING DEPARTMENT ENERGY CONSULTANTS, INC.
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. TABLE OF CONTENTS 1 Section Title g I Introduction . . . . . . . . . . . ... . . . . . . . . 1 A. Sunnmary. . . . . . . . . . . . . . . . . . . . . . 1 ? B. Equipment Identification . . . . . . . . . . . . . 3 C. Background . . . . . . . . . . . . . . . . . . . . 3 D. Inspection Obj ectives. . . . . . . . . . . . . . . 4 e E. Persons Contacted. . . . . . . . . . . . . . . . . 4 II Testing. . . . . . . . . . . . . . . . . . . . . . . . 6 III Corrective / Preventive Maintenance and . l Maintenance Records. . . . . . . . . . . . . . . . . . 10 l
- IV Visual Inspections of Diesel Generators. . . . . . . . 14 I
V Review of Component Problems / Failures. . . . . . . . . 15 A. Engine Head Cracks . . .............. 15 B. Turbocharger Failure . . . . . . . . . . . . . . . 16-C. Engine Block Casting Indications . . . . . . . . . 17 D. General Review of Problems . ...... ..... 18 Y General Recommendations. . ...... ........ 22 e l j l 1 l l l i l
- l. -
- .___-_...____.____._._e_____.__.______..-_.._.___-.___ .-
t . l - . .. , t 1 EVALUATION CY DIESEL ENGINE PROBLEMS AND TESTING AT SHOR MAM. NEW YORK . I. INTRODUCTION - 1 l l A. Suimmarv:
. An in depth assessment of selected operational problems was conducted which
{ included areas such as corrective amincenance, preventive maintenance and component fr.11ure. This assessment included detailed reviews of selected proble.:as identified in Long Island Lighting Company (LILCO) Deficiency Reports. Repair / Rework Requests issued by the Start-up ' Group and failure reports issued by LILCO, Delaval and other vendors. In addition, observation i of maintenance activities as well as a physical inspection of each emergency { diesel generator unit was conducted during both standby and, when possible. - running conditions. i l During the review of each item, an attempt was made to determine the following: (a) Was the work accomplished in accordance with approved proce.dures? (b) Were properly calibrated tools (if applicable) used during asintenance,7, , ,,, , , ,,,. . t (c) Were measurements, adjustments, t'orquing, etc. values within prescribed ranges? l l j (d) Were any trends detectable in readings or component failures? l l - (e) Were problems / fail'ures caused by design, engine vibration, incomplete or improper worknanship? A review of selected preoperational diesel testing was also conducted. This review included observations of in-process testing, revievr. of cast procedures, . reviews of completed test procedures and evaluation oL completed test data. "
i 1 During these reviews and evaluations of the diesel generators, a number of . problem areas were found to exist and are identified in the following report. In addition to specific problems / comments, which are identified, a number of ~ recommendations and observations are also included which should be considered for corrective actions. Although some problems are still occurring durinh operation / testing, the frequency at which they occur seems to be decreasing. Additional testing and corrective action is needed to provide a high level of confidence that the engines will start and operate reliably. Specific comments and l recommenda,tions are provided in various sections of this report. Section VI i l provides the specific recommendations for additional casting. Once these recommendations have been adopted (in conjunction with the recommendations of ' the LILCO Task Force), and the testing completed with no problems, this should
- provide the necessa q assurance that the emergency diesel can accomplish their design functions.
As identified in the recommendations of NUREG/CR-0660, the training and performance of personnel (including Q/A) involved with maintenance and I l operation of emergency diesels contributed significantly to the reliability of . l the various emergency engines. This same area appears to be a problem at Shoreham. The Repair / Rework program including records was falt to need' improvement. Additional review and evaluation is also needed of various test results as identified. in Section II. In addition. Section 7.3 provides recommendations l for further investigation as a result of the turbocharger failure. l .
; ENERGT CONSULTANTS, INC. ,
POR U. S. NUCLEAR REGULATORY COMMISSION REGION I , Contract No. NRC Contract No. 05-82-249 Parameter Purchase Order No. NRC-IE-82/83, Task 38 , Docket No. 50-322 License No. CPPR-95 Licenses: Long Island' Lighting Company
, 175 East Old Country Road Ricksv111a, NT Facility Name: Shoreham Nuclear Power Station Inspection Location: Shoreham, New York Inspection Conducted: April 25, 1983 - May 19, 1983 Inspector: Y. . r[/M iU Ga11ard L. Kunkle, Seni6r Consultant, Energy Consultants, Inc.
R. Ecuipment Identific'ation: Manufacturer: Engine - Transamerica Delaval Company Generator - Portec Electric Products Division Model: DSR-48 Serial Numbers: 74010, 74011 and 74012 Ratings: 4,889 horsepower 3,500 kilowatts (continuous) 3,900 kilowatts (2 hour rating) 0.8 power factor 4,375 kilovolt amps 4,160 kilovolts . 607.2 amparage C.
Background:
The three emergency diesel generators at the Shoreham Nuclear Power Station, Unit I, have experienced repeated problems during preoperational full load and endurance tests. The operational problems have included cylinder head
problems (5 heads replaced), rocker arm assembly hold-down bolt failures, turbochargar bearing failure and linear indications in engine block casting. D. Inspection Obiscrives: *
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, Provide an - independent review and assessment of emergency diesel generator operability, and the ability of the diesels to perform their design function.
based on a comparison of design capabilities / performance ratings (as described in the Shoreham yinal Safety Analysis Report, design specifications and vendor technical manuals) with actual operational data (as described in licensee preoperational test records). Witness ongoing emergency diesel generator testing, if applicable, and assess test results. Perform an assessment of past preoperational problems, including material fai'.ures, and determine the appropriateness of corrective actions to provide assurance of future diesel. operability. Review, as appropriate, licensee raccrds of emergency diesel generator preventive and corrective maintenance act: ens sine's January 1,1981 and c'ha licensee's written analysis of diesel l faiJures and corrective actions. Assess the need for independent ) NRC, contractor material testing and for additional lic.ensee material testing, 1 1 as may be required. 1 E. Persons contacted: , t* Long Island Lighting Comeany E. Youngling J. Rivello
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Stone & Webster Engineering Corneration i i R. Purcell N. Rudikoff T. ?aulautonio A. Stakutis l l R. Lavrance W. Dick T. Brown J. Kamayer W. Cook . T. Gray Transamerica Delaval, Inc. . L. McHugh - R. D. .Iacobs and Associates
. L Jacobs U.S. Nuclear Regulatory Comission J. Higgins E. McCabe H. Nicholas L. Bettenhausen
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II. TESTING
Background:
To verify - the ability of - the diesels to perform their design function, the operational data ist the preoperational test records were compared to the design capabilities / performance ratings described in the Shoreham Final Safety , I Actual Analysis Report, design specifications and vendor technical manuals. l testing was witnessed where possible., Summary: ' Portions of testing on diesel engines 102 and 103 were observed over a period of two weeks. This testing was being performed in accordance with In preoperational test procedures PT. 307.003 B-1 and PT. 307.005C TCN-1. addition, the results of a completed test procedure PT. 307.005A were reviewed. (It should be noted that the results of this completed procedure l have not been reviewed nor accepted by the LILCO Joint Test Group.) The comments resulting from these reviews are as follows: Comment #1: The Nuclear Regulatory Commission Regulatory Guide 1.108 l (Revision 1 August 1977) Section C.2(3) requires the emergency diesel generators to b'e tested at a load equivalent to the continuous rating for 22 hours and for 2 hours at the 2 hour rating. The continuous full load I. rating of each emergency diesel generator set is shown in Table Typical values of data recorded in PT. 307.005A for the full load run are shown in the last column of Table I. l TABLE I f Test Load Values
- Continuous Full Load Rating 3,500 3,510 Kilovarts (Kw) 4,225 4,160 volts (V) 480 607.2 Amps (A) 0.8 1.0*
Power Factor (PF) 4,375 3,5 13* Kilovolt-Amps (KVA)
- Calculated
.--..~-....-.,_...._,_n._.._.._-._____,....______.______________..__________..._.,...-__.
4,375) . and calculated KVA (3.513 vs. The low amperage (480 vs. 607.2) fun load tested at its continuous (Note: the shows the diesel generator was not power factor and KVA ratings. 1 rating considering current, lower reading.) l higher. voltage of 4,225 would only account for's 10 amp ine was not fully Typical data for the 2 hour load run also shows basis. the eng Note: l loaded te its 2 hour load racing on a current / power fuelfactor During the 2-haur fun load run at If the amperage load were racks were very near their fun travel stops. increased, the fuel racks any have reached fun trav , 110% amperage load was achieved. obtained during' the test did not I The lower ,than rated current load would probably have ' Note: simulate a lower power factor). normal bus load conditions caused by heating. (actu lag heat loss. The effects that are generator ltd therefore, were not effectively simu a e . l are capable of carrying their design emergency diesels To ensure the be conducted at the emergency emergency loads, additional esseing should 0.8 power factor. limits (voltage, amperage & KVA) while operating at a to Step 8.3.7 of PT. 307.005A states d 1500 load+ 100 diesel KVAA. gen Comment #2_: 3500 + 70 KW sa full load then' defines fun load as t record KVAR so the Table I of the test procedure records KW but does data cannot be verified. load of 3500 + 70, - l 1 full load run, however, this step only specifies a ' l 0 KW and does not address KVAR load. then the generator =ay f If step 8.3.7 definition of full load is correct,l abode 500 KVAR's were not have been at fu n load in stepThis 8.4.1 inconsistency since on y should be
.throughout the test.
maintained investigated and resolved. found that the ' ! In evaluating the recorded data, it was did not alway: Comment #3: recorded voltage and anperage) calculated KW (using the l
,+, - , - . , .,- - ,-. .. - - . . - , . - - - - . - - - . . _ _ . , . - - . _ . - , . . _ . . . - - - . , . - - - _ , , .----,----,n-,-, . , - . . , - , , . -
l \
+
.. l aset the acceptance criteria unless a power factor of almost ene (1) was . .
assumed. Some examples were observed where the voltage dropped and amparage decreased by about 10% and the recorded KW went up slightly - (KYAR .vould remain constant). These inconsistencies need further , evaluation to determine if test requirements were actually met. Conument #4: On April 27, observed that the official copy of PT. 307.005C in use for diesel testing did not contain TCN #1. (The step in progress had been changed by TCN #1. This TCN had been issued abcut two weeks earlier.) . l Comment #5: The data sheets in test procedure PT. 307.005C vere not signed by and therefore did not indicate who the data takers were. i Comment #6: Some instrumentation on ene diesels being tested were not i marked to indicate their calibration status as required by ANSI N45.2 and N18.7. For example, engine tachometer, cooling water charmometers, turbocharger air pressure, voltage, amperage and lube oil filter inlac and outlet pressure sages. i l Comment #7: Some data had been changed / corrected by write overs making i it difficult to read.
- - ~ . . .
i Comment #8: - In~. test procedure PT. 307.005A&C precaution 4.7 states l l diesel room temperature and humidity should be frequently monitored. l There was no objective evidence that this was being done. - \ Comment #9: Initial condition 5.5 in procedure PT. 307.005C was signed i off (with no exception indicatad) indicating the HVAC was in operation. ( However, the ventilation was not in normal operation as the ventilation damper was temporarily bypassed and failed open. 3 Comment #10: Step 8.4.1 of PT. 307.005A states " ensure total KVA of , generator does not exceed 4375 KVA". Since there is no method provided ! to measure or requirement to calculate this value, it is not clear how i
- this requirement was met.
l e
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Comment #11: The diesel generator load values in Table II of , FT. 307.005A are not recorded in the corre c units. The table specifies
, KW while values are actually recorded in MW. - -
Comment #12: Various . steps in PT. 30.7.00SA Q4re designated to be witnessed by Operations Q/A. The following steps have been completed but were not signed by Operations Q/A to indicate they witnessed the steps: 8.3.9, 8'.3.11, 8.5.3 and 8.6.1. - Recommendation #1: The readability of seine of the test instrumentation does not seem to be accurate enough to meet the <'eest requirements. For example, the minimum subdivision for KW on the recorder was 200 KW while the tolerance band specified in the procedure"Was +40 and -19 KW. Similar problems azisted for amperage and voltate. Test instruments should be accurate enough to be compatibie wich' the tolerance of the acceptance criteria in the procedure. e.:g., the ' readability of most analog instruments is one-half the smalle'wS scale ~ subdivision. The high-speed recorder and charts should be analyzed to verify that their accuracy will actually permit reading (inferpolating) these charts to one-quarter or one-eighth of the smallest s6 ale subdivision as necessary l ( co assure compliance with the test requiricents, e e So
III. CORRECTIVE / PREVENTIVE HAINTENANCE AND MAINTENANCE RECORDS . l
Background:
l , l l Approximately eight percent of the wintenance records (including Repair / Rework Requests, Rework Supervisor ' Work Suasaaries and Quality Assurance l Verification Reports) were revieval to determine if the work was accomplished I in accordance with all vendor technical requirements. This review also determined if the maintenance and maintenance records properly implemen'.:.d both local and NRC requirements. In add $ tion, problems were reviewed to determine (where possible) if the " root cause" had actually been identified and corrected. ' i l Summary: I In many cases it was not possible to verify, based on the maintenance records ! idencified below, that the work had been properly conducted in accordance with both tachnical and ad= M atrative requirements These proolens fell into the . following categories:
- 1. Torquing -
The Delaval Technical Manual, Volume I, Appendix IV provides a table of torque values to be used for various threaded fasteners. This table also stated that all torque values are based t on the use of a thread lubricant consisting of a 50/50 mixture of graphite and engine oil. e Comment A: Some maintenance records indicate incorrect torque values may have been used. For example, Repair / Rework 408 indicates the rocker arm assembly was only torqued to 120 f t 1bs instead of . the required 365 ft 1bs; Repair / Rework 417 indicates the rocker arm assembly and sub cover were torquad to 365 fe 1bs, (i.e., l overtorqued) although the sub cover is only required to be torquad [ co 120 ft lbs. The consequences of over or under torquing should be evaluated. w.. . ~ . ._, . , ,_ . . , . _ - , . , . - , . , , , , , . _ , , , , _ , _ , . . . . , . , ~ _ _ _ _ , , . , _ _ ~ , _ . , , , - _ . . _ _ _ . , . . _ ..,-_.r . - . _ _ , . , . - . - - . . ,
l l l Comunent 3: A number of amintenance records do not prov,1de any . documentacion or assurance that threaded fasteners were properly torquad since no torque values are recorded in the space provided - (Start-up Instruction No. 6) and since the records do not provide any reference to the use of calibrated torque wrenches (i.e. , there were no Measuring and Test Equipment (MATE) numbers and calibration due dates recorded in the- space provided). The following l Repair /Rawork Packages are typical of this type of problem: 2 (1) 751 - no torque value and no M&TE number (2) 577 - no torque value and no M&TE number i (3) 596 - no torqua value and no M&TE numbers (similar work on 805 & 808 had required information) i (4) 554 - states "no torque value, vendor specs" (5) 637 - no corque values recorded (6) 712 - no MATE number for torque wrench used on head studs (7) 394 - no torque values and no M&TE numbers (8) 423 - no corque values and no M&TE numbers Comment C: A number of maintenance records do not provide any assurance that the required thread lubricant was used .during , reassembly and torquing. Some records specifically indicate "none" . or "NA" in the space provided on the form. Other packages did not include a copy of this completed form to show a lubricant had been used. Start-up Instruction No. 6 provides a place for recording type of thread lubricant. Typical examples are found in the following Repair / Rework Packa3es: 9 s,. , ---v-r,,--mg , - , - - , , y,_,y.,-7,.,,,.-y,.,-n,,,v,y,-~~r-,,,wn.n,,n,_,.,,,,.-.,,--.,, m _.,, _, , _ , , , - , , , , - _ , ,_._,-..--m, . , - . . , - , , . , , , , - , , ,
j . , (1) 612 and 744 - indicate lubricant was used on head studs, , other studs and bolts were not addressed (2) M - states "none" ! , _( 3) 670,- states "NA" , i (4) There is no reference of any lubricant in packages 596, 360, 359, 511, 636, 637, 714 and 820. Comment D: In many of the maintenance records, the Quality Assurance verification report is so brief or general it is not
,possible to deternise 'what was witnessed and verified. - Typical examples are found in the following Repair /Revork Packages:
612, 349', 351, 360, 670, 712, 423 and 577. Comment E: Some maintenance records indicated repairs and/or inspections were performid but the acceptance criteria is not clear. Typical examples can be found in the folleving Repair / Rework Packages: ' (1) 751 - i jacket water pump was disassembled and the pump impeller was " inspected and found to be scrisfactory". It is not clear what this acceptance was based on since no measurements were recorded and instructions do not specify what kind of inspection to perform (i.e., visual,
. asasurement, dye penetrant).
- (2) 546 - During repairs to a jacket water pump, this package .
states " started lapping and blue checking bore to shaft. Attained 85% contact on blue check." No reference is made to any acceptance criteria for the required percentage of contact.
- 2. Maintenance Procedures - Seteral Repair / Rework Packages were found which indicated the repair work had been pqrformed in accordance
.O 1
with verbal directions from the Delaval service representative. The , specific directions or adjustments were not normally recorded making it impossible to verify that the work was complaced in accordance - with the technical specifications in the Delaval service manual. - One example was found where a thrust reading outside the specified tolerance was apparently accepted based on verbal direction of the vendor. Typical examplas of these problems are found in the following Repair / Rework Packages: Comment A: 590 - The work summary in this package " checked total thrust of ' rotor assembly - 0.007* (okay from Al Scott Delaval representative)". A Delaval letter of December 6,1982 (attached to LDR-926) states the Elliott specifications call for a thrust of 0.008 to 0.018. Comment B: E - The work summary in this package states " adjusted rocker arms accordingly as per Delaval representative". Comment C: 546 - The work summary in this package states " installed water pump with new gasket, tighten down bolts to representative '
- approval".
( comment D: , 554 - This package documented disassembly a jacket water pump for inspection and replaced the impeller nut. The work summary states "no torque value, vendor specs". l . 1 l l l l
4 IV. VISUAL INSPECTION OF DIESEL GENERATORS ,
Background:
Visual inspections of each diesel generator unit was performed. When possible, inspections were also performed while the engines were . running. These inspections were performed to determine the general condition of each engine and detect possible abnormal conditions. , Summary: While no major problems were observed on any of the engines, some conditions were noted which should be corrected to ensure future problems do not occur. Several other conditions were observed which should be evaluated to determine the need for further corrective actions. Comments resulting from these inspections are as follows: Comment #1: Many instrumentation; contral and gage lines (1/4 inch to 3/4 inch size) are inadequately braced and vibrace excessively during operation. Some lines appear to need additional brackets while others
,have been removed from the brackets provided and vers never reinstalled.
For example, the lube oil supply line to the turbocharger failed due to vibration while in its design brackets. Comment #2: P. ste on each diesel specified required torque A label values. These values do not all agree with the torque values currently in the technical manual. Comment #3: Some bolts on the air inlet elbows to the head were loose .
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and partially unthreaded apparently due to vibration during operation. - Some bolts had washers, some lock washers and others no washers. The application of washers and/or lock washers should be specified.
l , . .
-V. REVIEW OF COMPONENT PROBLEMS / FAILURES A. Engine Head Cracks -
Background:
LILCO Deficiency Reports 1040, 1065, 1056 and 1141, various Repair / Rework Requests and correspondence with Delaval docu:nents the identification of cracks in three cylinder heads. The Delaval Failure Analysis Reports indicate the ' cracks found in the three cyls.nder heads occurred as a result of manufacturing defects (hot tears resulting from sand inclusions in the casting and uneven cooling). The small amount of leakage that might occur would be blown out with the exhaust. Since these cracks were self-relieving and non-propogating, Delaval stated they would not affect operability or availability
. in stand-by service. The Delaval reports also indicate improv'ed casting, manufacturing and testing techniques would preclude cracks in the latest head
- design. ,
LILCO letter SNRC-873 indicates that a leak detection procedure recommended by Delaval will be implemented until the permanent correc,tive action can be accomplished. This permanent corrective action will install cylinder heads of the latest available design. l' Summarv: LILCO's corrective action of installing the latest design heads should i eliminate this problem once the work is completed. This work is currently scheduled to be completed on a non-controlling basis. The leak detection procedure recommended by Delaval would identify any future cracks should they . occur. . Based on a review of the actions being taken by LILCO, additional independent NRC/ contractor material testing is not recommended. f
. . ..- - . ~ . . _ -- -.. - - - - - _ - - ._ - . - _.-. - . - -- . . . - , ---
r J Recommendations: (a) Since water leakage / build up into a cylinder during long idle - periods could have drastic consequences in an emergency start, it is recommended that if an engine does not have the nev* design heads
, installed, then it should be barred over with the indicator cocks open on a weekly basis after reactor critical testing has started.
This barring procedure, in conjunction with the barring procedures recommended by Transamerica Delaval, should acsure the engines will operate satisfactorily with the existing heads. (b) Since Delaval has indicated stricter manufacturing controls assures the new heads are a high quality product, consideration should be given to either auditing or monitoring the production of some of these new heads or performing' detailed receipt inspection and testing of one or two of these new heads. . B. Turbocharger Failure .
Background:
LILCO Deficiency Report h26 documents the failure of a turbocharger thrust
- bearing. The-initial evaluation by Delaval indicat(d the failure occurred due i
to a missing guide vane on the nozzle ring. A subsequent report from the turbocharger manufacturer (United Technologies Elliott) concluded the missing blade (vana) had failed in service apparently due to mechanical fatigue. In addition. Elliott indicated that additional analysis was being conducted on
, the nozzle ring and that pressure and temperature readings just upstream of the turbine inlet casing during a rapid start-up cycle would be helpful. .
Summarv: Based on the type of failure ~(mechanical fatigue), it is recommended that this not be considered an isolated occurrence until it has been determined exactly what conditions caused the fatigue failure.
; Recommendation: .
Consideration should be given to: - (a) Checking the other turbochargers for possible cracking (b) Evaluating the possibility of the missing blade having been knocked back into the exhaust manifold as postulated by Elliott. C. Engine Block Castinir Indications
Background:
LILCO Deficiency Report #1224 and Repair / Rework Request numbers 867, 868, 369, 870. 871 and 880 provide the details of Stone & Webster Engineering Corporation's (S&W's) investigation s.nd engineering evaluation of linear indications which were found in the cam ' galley area of the engine . block
- casting. ' The investigation required the indications on each engine to be checked and mapped using non-destructive evn=4 nation. A similar design engine with a substantial number of operating hours was checked by SW engineers using nondestructive examination. Indications were found of the same l' approximate siza with no evidence of any propagation. S&W engineers found similar indication on a new engine block casting at the factory. This shows the indications occur during manufsecure and are not a result of operations.
Calculations by Delaval showed the regions where the indications are located are subject to compressive stresses which would not cause the indications to propagate. Discussions with S&W lead engineers indicated Delaval is conducting tests on an operating engine in order to verify their calculations and will issue a report when 'this testing is complaced. Based on their . evaluation of these indications, S&W has concluded that this indication will present no problems to the operation and reliability "of the emergency diesel generators. e
Summarv: . Af ter a review of the actions taken by S&W and Delaval and discussions with '* the S&W engineers, who conducted the evaluation, it is felt that their actions v'e ra adequate and the conclusions correct. Howeve the test results should
-be' reviewed to ensure they verify the calculations.
D. General Review of Problems 1 .
Background:
i l During the detailed review of various Deficiency Reports, Failure Reports and I Repair / Rework Requests, a significant number of problems or errors have been I identified which seem to have occurred due to errors and incomplete or' , improperly completed work by the manufacturer. Attachment I to this section provides examples of specific problems that fall into this category. Summarv: t
, A large number and variety of problems that have been experienced can be attributed to vendor workmanship. These errors, in conjunction with the prob 1' ens identified during audits of Delaval's Quality Assurance Program (audits /reaudits conducted October 1975, February 1976 and June 1976),
- indicate a weakly implemented Quality Control Program.
1 Recommendation: , i-Although the number of problems is decreasing significantly, they have not been completely eliminated and, therefore, reliability has not been . ~
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' demonstrated. Based on this, strong consideration should be given to continued operation or testing until problems have been eliminated and the engines run reliably. Once the required testing has been completed and all problems corrected, at least one engine should be started and run for the design seven days at a nominal load of 3,500 K'J.
t-, .
The actions taken b'y Delaval to eli=inate these. quality-related problems . should also be determined and evaluated. This would ensure problems vi-A future spara parts will not occur.
- To provide the confidence factor that the emergency diesel engines will operate reliably, the periodic surveillance cascing should be incre>ss ed to perform a four hour load test each month. If at the end of six months no failures have occurrade return to the surveillance tasting specified in the technical specifications.
. i t\
N e o
% Ts L
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a 1; .
, ATTACHMENT 1 -
Y i& CENERAL REVIEW OF PROBLEMS - g - A meno in this package from a Delaval representative indicates the casing dis:harge on a jacket water pump was found partially blocked by excess casting material. 442 - E&DCR-F41289 - attached to this package indicates Delaval supplied a
, :> jacket water pump with the wrong impelle'r.
1 551 - (See LDR-0832) - A meno attached to this package indicates a jacket water pump had been assembled with an extra washer behind the impeller castle
. nut and that the impeller had been machined to the wrong drawing which had
.been provided by Delaval. A second pump failed and investigation showed the
.y i impeller had been improperly installed at the factory.
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4
' r 577 - A Delaval Failure Analysis Report (attached to E&DCR-F43525) indicates the jacket water pump shaf t failure was induced by an improperly tightened e impeller hub nut. (There were no records to indicate this pump had been
. disassembled since it left the factory.)
p . 5 -p
.-s LDR-816 - This deficiency report indicates incorrect springs were installed on the internal relief valves of the engine driven fuel alli pur.:ps.
Q3 359 ud 360 - (See LDR-654) - During a pre-sta'rt inspection of the gear cases,
., it'sas found that two of the engines bere missing some fitted bolts required on tha'can gear. Delaval drawings require drilling holes and installing and
'1' corquing these bolts after final engine timing. .
701 3 7H - (See LDRs 1006 and 1024) - During inspection of the Governor Drive assembly, the following problas were found: t i (a)- Coupling grid was broke.'. due to misalignment of the governor (b) A key of the wrong size was found installed on one engine 4 _-- - n.- _ - - _ _ _ . _ _ - - _ _ _ _ _ - _ - . _ _ _ _ _ _ _ - . . _ _ - _ _ - _ , _ . _ _ _ _ - - . _ _ _ - _ _ - . - . _ - _ _ _ - - -
~ - . . .- . _ = - . .-_
r .
, e VI. GENERAL RECOMMENDATIONS -
Beckaround: . During the review of the Diesel Generator operations, testing and maintenance. a number of conditions were observed which did not specificany violate or , deviate from requirements but which did, in the opinion of the inspector. {- indicate weakness or az:eas which could be improved. Other conditions in this
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category are those for which insufficient information was available to make a judgement.'and should be considered for further evaluation. Summary: 1 The fonowing list _of observations and recommendations should be concidered for further evaluation and/or possible corrective action: 6 Recommendation #1: Repair /Rawork Requests do not reference specific repair procedures. Tag normany only reference the D' insel Construction specification SHI-089. This makes it difficult or impossible for .ither Q/A inspectors or other reviewer / auditors to determine what instructions L were actuany to be fonowed. A system that requires identifying the speeffic repair procedures would be a major improvement. This would
- allow Q/A personnel to review the specific procedure and establish hold / witness points as necessary. This could be similar to the procedu:e for Maintenance Work Requests.
Recommendation #2: Based on che problems identified in the 1975 audit'of Delaval of the failure to have calibrated torque wrenches plus the lack
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of adequate documentation in maintenance records for torque value makes . it impossible to ensure all components have been properly torquad. Based
- on ,the work completed to date, it is recommended that all components /
parts should have their torque values verified by analysis or tests. 4 Recommendation #3: As stated in other sections of this report, s r.,me problems or failures are still being experienced when at engine is run for testing. Some problems result in the engine being shutdown for A E
>~w, , -v e r ,w,z-.,vY -r - m s w ,w -m- e m-,-w,,w- w w e .e,--ww-w s. ,- m-w n -- mm - -e--enw--ma-r.-we--,---mo-.-m<eme -,mm--we-wn-e-=---se,- , - -- + + , =a.--,
ATTA N nT 1 (CONT'D) . (c) A coupling half was found pinned to the coupling adapter although - this pin was not shown on the Delaval Drawing. 712, 744, 408, 636, 661, 663, 670, 714, 715 and 717 - (See I.DRs 1040, 1065, 1056' and 1141) - Part of the problems with the cracked cylinder heads was attributed to manufacturing defects and thin castings. The factory inspections and testing had failed to identify these deficiencies. 046 - (See I.DR-0503) - Lube oil cooler tubes leaked due to improper rolling of tubes inta the tube sheet which were not identified by vendor quality control. 236 - (See LDR-0560) - The lube oil pump suction line on one engine was found without a drilled passageway for the relief valve. This problem was attributed to an oversight at the factory. M - During a routine gear inspection, an extra loose bolt was found in the
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gear train. The bolt was badly beaten and chipped. M e 4
. + ,
t convenience to correct the problem. Other problems such as lube oil line . failure and jacket water temperatura pneumatic s$ritch failure resulted in immediate engine shutdown. Testing / operation should continue until the - engines'all operate reliably. After aJ11 work and testing is completad, it is recommended that at least one emergency diesel generator should be scarced and run for seven days at about 3,500 KW. If a failure occurs, testing should continue until all three engines have demonstraced their l- - ability to operate reliably under load for the seven-day period. i ' \ I i Recommendation #4: Obtain the results of audits performed on Delaval by other utili::ies and evaluate their findings and corrective actions (i.e., j Texas Utilities, Gulf States Utilities and San Diego Cas & Electric). Based on .this information, determine the need for further additional audits of Delaval. , . Recommendation #5: The engine exhaust inlet and outlet elbow from the turbocharger are nai -21sted and could present a fire hazard from a fuel oil or lube oil line failure. The need for insulating this a as should be reconsidered or some other assurance provided that shows such a fira could not occur. Recommendation #6: There is a substantial opening (abcut four (4) inches trids. and several feet long) 'oetween the flywheel and the protective cage around the generator. Since this opening is on the top of the gsnarator adjacent to the baring device, it presents a possibility of items falling into the generator causing damage or short circuits. Consideration should be given to install a protective cover over this opening. Recommendation #7: In arvaral of the problems / failures which Long Irland . l Lighting Company has experienced. Delaval already had an improved / upgraded replacement part which effectively eliminated the problem. S&W and LILCO should make a strong effort to have Delaval supply them with a list of modifications, design changes, product upgrade, etc. which have l: been made to this type of engine since the LILCO engines were l manufactured. LILCO and S&W could then review this list and decide which 1 l of the modifications they want to implement. l. s.-- - .\m,,--+,- , mm_.___.,_-,,,,,,,m.,_.,-,-.-.
~
t
- Recommendation #8: During operation, a significant number of fuel oil and '. , ,
lube oil leaks are apparent. These leaks keep one individual busy r I' cleaning up. During an emergency, personnel may not be available to keep - these leaks -cleaned up. This could result in substantial accumulations presenting a fire hazard. Action should be taken to eliminate as much of this leakage as practical. Observation #1: Some of the LILCO Maintenance Support Division pe.sonnel have completed a diesel maintenance training program a few months ago. There was insufficient time available to determine the diesel experience l or training for maintenance personnel from the construction groups who have also performed repair work on the diesels. Observation #2: As noted in other portions of this report, there are examples that vendor field representatives operate somewhat informally at
- times . in directing repairs. While he is assigned in the field, the Delaval representative is not clearly under the umbrella of the Delaval factory quality assurance plan. The utility (LILCO) personnel tiend to
. accept his comments / actions since he is the " vendor expert". When a Delaval representative is performing or directing work at the site, his actions should comply with the LILCO Q/A Program just the same as any other plant worker.
I L Observation #3: The jacket water pumps do not have unique serial numbers asking it very difficult or impossible to maintain traceability especially during multiple pump changeouts or maintenance. Observation #4: The TSAR response to NRC question (request) 223.85 l states, "As shown on Figure 9.5.7-1, a check valve prevents lubricating i oil from being circulated through the turbocharger" when shutdown. l However, a subsequent modification (E&DCR T-34540) has now added a small lube oil supply to the turbocharger in the shutdotn condition. This response and figure should be reviewed and revised as necessary. Observation #5: In general, it was felt that the quality assurance., engineering and testing ad=inistrative procedures that applied to
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start-up activities were weakly implemented. A specific concern is the
~
fact that most of the problems identified in this report have existed for over a year and were not identified and corrected by supervisory reviews ' or the audit program. G 9
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4 0 6 C LP-30 ATTACHMENT 6 I S
Q ) g ,Ed,& ,@ LONG ISLAND LIGHTING COMPANY E EXECUTsvE OFFICES: 250 OLD COUNTRY RCAO
- MINEOLA. NEW YORM 11501 isieltas.aa44 i
EDW te. SA8D8tCTT
.... e..m December 2,1983 -
)9% N O
1 Robert E. Smith, Esq. h r N hk ~%.g'4-Guggenheimer & Untermyer 80 Pine Street D 10005 New York, New York
Dear Mr. Smith:
This letter is sent to you in your capacity as counsel to Transamerica Delaval Incorporated (Delaval). As you know, on August 12, 1983, the crankshaft in emergency diesel generator 102 at our Shoreham Nuclear Power Station failed in the course of performance tests of the engine. LILCO retained Failure Analysis Associates (FaAA) to conduct a thorough investigation of this failure. In the course of this investigation, cracks were found in the crank-shafts of diesel generators.101 an.1 103 as well. FaAA's final report on the cause or causes of the crankshaft failure demonstrates that the crankshaft failure occurred as a result of inadequate or defective design. FaAA also investigated cracked connecting rod bearings and cracked pistons discovered on the engines. FaAA's interim report on the cracked bearings indicates those failures occurred as a result of a combination of causes, including inadequate or defective design and uanufacture. FaAA's investigation of the cracked pistons and other matters observed in the inspection of the' engines is continuing, but preliminary indications are that these, too, occurred as a result of defective or inadequate design. Prior to the crankshaft failure, LILCO had experienced a number of occurrences attributable to defectively designed or f abricated diesel generator components, including three leaking cylinder heads, defective jacket water pumps, leaking fuel oil injection lines, inadequate turbocharger thrust bearing lubrication, inadequate piston skirt to piston crown attachment, broken rocker arm shaft bolts and cracked sub-cover assemblies. While these occurrences were generally of the type experienced in the shakedown of large diesel engines, they appear, nonetheless, to be attributable to defective design or fabrication. e e
1 t ) RobGrt E. Smith, Esq. Dscambar 2, 1983 d Based on LILCO's currently available information, LILCO believes the defects in the diesel generator sets provided us by Delaval constitute a breach of the contract between LILCO and Delaval for the purchase and sale of those diesel-generator sets , including but not limited to a breach of warranties contained in and arising out.of that contract. ' This letter is solely for the purpose of providing notice of the breach. Nothing contained herein should be construed as a release of any other claims that LILCO may have against Delaval or as a waiver of any rights and remedies LILCO may have in this matter. Although LILCO is now giving Delaval notice of claims, we believe it is in LILCO's and Delaval's best interests to pursue aggressively the prompt repair and licensing of the Shoreham diesel generators. We believe substantial progress has been made toward this goal and hope that Delaval and LILCO can work together in the future to complete this important proj ect. Sincerely,
<!& h w ~
EMB:1bs Edward M. Barrett 4
Sc. LP-35 \ ATTACHMENT 7 O 9 i ,c e s , - - , - . ,
KA. S.r j q .. ,{ j
, .'s, Urt: Tac!T/T!s NUOLE/ R 8.EGUL ATORY COr.*:.*!SSICN -
y .~ .==e 4ersamste :. e. c. nser f i
.s[.....f 5 7 Octocer 21, 1953
/
Docket No. 50 416 MEMORANDUM FOR: Chairman Palladino' Comissioner Gilinsky Cor=!issioner Roberts Cemissioner Asselstine Oc=issioner Eernthal FRD*: Carrell G. Eisenhut, Directer Division of Licensing 1 SUEJECT: NEW INFORMATION CONCERNING TRANSAMERICA DELAVAL (TDI) EMERGENCY DIESEL GENERATOR 5, BOARD NOTIFICATION 83 160 In accordance with NRC procedures for board notifications, the following informatic . is being provided directly to the Comission. The appropriate boards and parties are being provided with a copy of this memorandum. The-inferratier, is acclicable to Grand Gulf (an uncoritested case), which will be before the Comission fer full power autt orization ! in November,1923. ~ On August 12, 1923, during post-modification testing, the main crankshaft on
-ene of the three emergency diesel generators (EDG)'at the Shoreham Nuclear Fower 5 ation failed and croke into two pieces. The a'pplicant subsecuently inspec ed the remaining two diesel generators at Shoreham and identiftec "
additional flaws in the crankshafts of those machines in locations similar to the failure of the first machine. A more detailed description of the failure is_ contained in Enclosure 1 (IE Information Notice No. 83-58). The EDGs at Shoreham were manufactured by Transamerica"DeLaval Incerporated* (TDI). IDI has also provided EDGs to several other nuclear power plants (see Enclosure'1). The only currently operating reactor with TDI diesels is Grand Gulf. The TDI diesel at San Onofre is used by Unit 1, which is shutdown for
- seismic modifications, and the diesels at Rancho Seco are not yet installed.
Resides the failure of the crankshaft at Shoreham, the staff has noted the cecurrence of many minor problems with TDI EDGs, which are sumarized in Enciosure 2. The staff would expect minor problens.to occur during the l- startup te", ting of any large piece of macninery, such as a diesel generator, L tut the nucher of cinor probler.s experienced by the TDI machines in nuclear y rarvice appears to be arncrmally high (also See Enclesure 4). l L 8308.*,10o50
- t- e 3.) - 4 2-Adci-icr. ally, curing vende- ins;ect' ens c' TDI which were ce #cW recer.tiy 53 Regier :Y, fr response t; ellecatiers. 'hc staff identified ccnditiens
'which ' imply snat portiens cf the TDI Ouelity Assurance (G) Program have net 5+cn carriec out in accordance with the provisiers c' 10 CFR 50, A;;endix 3.
. Regien I',' has referred the U prcblems to the Office cf.Irvestigations, which has reauested that details net be revealed to avoid cerrre:-Msing the in.
vestigation. As e result of an inspection performed in July 1983, the staff identified a potential violation and several potential noncerfe-: ences v.t.ich-are described in IE Inspection Report No. 99900334/83-01, dated October 3, 1983 (Enclosure,5). , Th.e Sherenam applicant is investigating the crerksheft failure, but does ne: e r.c er.- te publish a report U + 1 later ir. October.. The staff has asked the t;;.t tr. to accress a series of ge:tiert. cencernir; t5e Shcrehe:- E03 cast;r, fabricatien, cperation, and maintenance in itr. *ailure report (see Enclosure 3). A similar list of ouestiers is being developed for other applicants. The identification of OA problems at TDI, taken tocether with the number of operational prcblers and the Shoreham crankshaft failure, has reduced the staff's level of confidence in the reliability of all TDI diesel ger.erators. The staff will recuire, on a case by case basis, a demonstration that these
. cencerns are not applicable to specific diesel generators because ef suc-secuert insoections or testir.g performed specifically to address the cheve -
matters. Further developments and additional information on this sub.iect will be reported to the apprcpriate Boards. -
\. s s
. .t I ' .t - r -
'l DreNG'.'Eis'erht:i,c. D'i t, +rectar sL.
Division of Licensing
Enclosures:
(1) IE Information i:ctice P?-58 (2) Sur: nary of DeLaval DG Preblems (12/S0-8/83) (3) Sur=ary ef 5*.ptember 2,1983 EDG Meeting on Shoreham (di IE Information Notice 83-51 . (5) IE Inspection Recort Ic. 99900334/83-01 With October 3,19E3 Transmittal 1.etter to Trans* erica DeLaval, Inc. -
.cc: See next page e . .. .e . . . .e ene.e. *
- dp
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- - . I y ,.
05URE 1 SSINS Nc. E!35 IN E3 ::
- UNITED STATES -
NUCLEAR REGULATORY COMMISSION 5 OFFICE OF IN5 FICTION A:C EIFORCEMENT
. . WASH *NGTON, D. . 205E5 August 30, 15E3 IE :.JORMATION NOTICE HO. 83-58: TR'ANSAMERICA DELA'/AL DIESEL GENERATOR CRANKSHAFT FAILURE Acdressees:
.si nuclear oewer facilities holding an operating license (OL) or a construction pe mit (CF).
7::-cese : This infomation notice is provided to bring to the attention o' licensees f and ccr.struction permit holders a recent event at the Shoreham Nuclear Station.in whien a ciesel generator crankshaft failed during post-modification full 1cac tasting. The Nuclear Regulatory Comission staff is reviewing the problem and its effects. If the evaluation so indicates, the NRC may request explicit licensee or CP holder action. In the interim, we expect the addressees of this infermation notice to review the information herein for applicability to their facilities. No specific action or response is required at this . time.
.Descris-ion of Circumstances:
Af ee installation of eight new cylinder heads, emergency diesel generator' (E G) Ho. 102 failed during post-modificaticn testing when its crankshaft - asse. bly fractured at the crankpin and crankarm (web) on the generator side of' the Cylinder No. 7 crank. This failure occurred during the last 15 minutes of testing at the two-hour overload rating. EDG-102 had a total of 12 hours and 25 minutes of two-hour overload testing When failure occurred. Its installed i c a r. shaft assembly ~has a crankshaft diameter of 13" and a crankpin ciameter cf
. 11 . Replacement crankshaft assemblies with 12" diameter crankpins are being prc> cured. ,
l 1 e l Subsecuent to this failure of EDG-102, the licensee examined the crankshafts of the two other diese1 generator units at the Shoreham site, EDG-101 and EDG-103, ! . ' by opening the crankshaft aret. The examination of the EDG-101 crankshaft
. assembly showed cracking on the Cylinder No. 7 crankWeb (generator side) anc cye :enetrant indications on the cranks at Cylinder Nos. 3 and 5.
E).ami..ation of -he EOG-103 crankshaft assembly icentified a crack about 2" lor.g and 3/8" deep on the Cylinder No. 6 crankweb (governor side) and a cen-r.ec-ing rod to crank:in bearing f ailure on Cylinder No. 5. The bearing failure drcc'.ved breaking off of a;;roximately a 1" x 3" piece and overnetting cf l . es w p,te-v. +--- ->p '*a-ap e .i --.-,--ye y -e,g.pgq.gm,--u-r,,- y3ww,w e i.i - .,.g,,e,.g-- p,.- ,
,-,,,p. -,-w,_ y.-%,p-. 7,mewe.myeis..,,y.- .-g--. ,.-. wy ' - -
1
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IN E3-58
, 1 Augus- 20, 1953 Page 2 of 2 j
i the surr:undin; area for ab ut 2". Mest of the r,ther cracks fcunc are 'simi* ar it'.:ca-ict and Orientati:n to the one which resultec in CG-IC2 crankshaft , asses:1y fracture. Tra..sanerica Delaval reported that the following nuclear sites have Transamerica Dela"-1 diesel generators: Shereham Perry - Midland Grand Gulf Bellefonte - Ha rtsville Ca,awsa WPPS Phtpps Bend
. San Onofre Comanche Peak River Bend
- yogtle
- Rancho Seco -
Shearon Harris Ciinch River The ;relhinary'information from the manufacturer is that the diesels at Shrraha=, F.iver Band. and Rancho Seco" are eight cylinder in-line engines. However, the crankpin diarater is 11" in the Shoreham units and 12" in the ur.its n the other two sites. The diesel engines at the remainder of the shes listed above are of a "V" desit)n and have 12,16, or 20 cylinders. he shaft material for all the engines is the same, with the pessible excep-ion
- 1 ;*.e 20 cylinder engines. All the engines are designed to have appr:ximately the sama brake mean effective pressure. The torsional systems of the engines differ. At this time 'it is not clear to what extent other diesel generators
. =anufactured by Transamerica Delaval are vulnerable to the same or similar .
failures as these experienced by the Shoreham engines. - If y:u have any questions regarding this matter, please contact the Regional ! Ac=ir.istrator of the appropriate NRC Regional Office, or this office.
. . ;,. s . . ..' . L,
- y .
***"{-
. Edward L. Jordan Director
. Division of Ertrgency Preparedness ar.d Engineering Respense Office of Inspection and Enforcement Technical
Contact:
W. Laudan, IE (301) 492-9759
Attachment:
*fs cf Recently Issued IE Information Notices-i.
. ..i .
a ..:. : 5e:: units art not installed; they will be used to replace the axite r.g etesel generators. c ..
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. cc: SECY OFE 03C EDO ASLB FOR:
Shorenam 50-322 (Brenner, Ferguson, Morris, Laurenson, Kline, Shon)
. Perry 50 A40/441 (Blech, Bright, Kline)
Comanche Peak 50 445/446 (Bloch, Jordan, McCollan) Midland 50-329/330 (Bechhoefer, Cowan, Harbour) Catawba 50-413/414 (Kelley, Callihan, Foster) Clinch River 50-537 (Miller, Hand, Linenberger)
-ASLAB FOR:
.Snorenam 50-322 (Rosenthal, Edles, Wilber)
Clinch Ri.ver 50-537 (Edles, Johnson, Wilber) e e f 9 l e e
' e e 9 e
9 D e S 9 e
- ee e ee e ee e- 4e e
e . ENC'.05UP.E 2 c y; p.: ,_ ,a-::.- e I . , , . . . . . . . . . . . . . . . . . . . . . . . . . *,,,... . L . .1 * .; ; . . * . 1;*. 41 *
- 1 *. *. . . *. * -
- 4. 1* *.e.*.'.**.. .= . ' . = .e.. . . . . . .
.t *..* .?. * ?. ?. *s - 3. .* :.I.*.."* . . ..* ?. . v. i. *. ;
- CE/12 /E2 e Crankshaft f ailure o Esing inves-igg eg ,
e Cause un.neca., r as ye. . e Snorenam ED1-102 - 03/20/E2 e holdcown capscrews, rocker arm assy. e re iaced wi n new casi:n e Shorenam EDG-103 e 701 says isoia ed failure lI/;i/12 e cracked cylin:f r neacs e re:iaced .i-. ne 7:.: g es i:-
~
e water in cylincers - e TDI says n: affe:. cr. c;e ra tii i:*.- e Shoreham EDG-101,-102,-1CI - . - /03/53 e hi-press fuel line e recieced Li:n r.ew destgr. e manufa-:gring defects fuel line w/s eei snr:ud a Shoreham ED3-102,-103 . e Also failed.at Grand Gulf on 8/2/83 re;:r ed dy 3 rand 3;1f cniy 12/13/12 e u5cualified centr:1 cabies e . e failed IIII flame tes- - , 03/17/12 e jacke* Wa*er ;':J 0 shaft failures e new desi;?. a f
- e r f,0 re i gt, f ai* .*r e fatigue cracking at snaft keyway e new cesiin failed .
e Snoreham E35-102 (50 hourt}, -103 e 3ro otsi;n inciu:es : new (170 hours) . i=;elier =at') . , recevin;
- shaf t key, size c' rut washer, ns a s s e
- : *.y i r.s -.: 1: s b7/22/52 e hi wa ar jacket ta=p. tri; e design deficiency I e closed cooling cutlet valve e incorrect valve pos. indication e Grand Gulf Div. 2 05/23/52 e g:ve rner flex. drive ceucigng e replaced w/ neoprene e misa:;1ication of materials e ,ss:rene in en:ed for a :: spheric
.a;:lica* ion ,
e sting use: a* hi-tem:. cil environment inside gear case e Grand Gulf
*6
... _ . , . . - _ . _ , _ _ . . - _ . - - . , . . _ . , , , . _ _ _ . . - _ _ _ _ . . , _ , ,,_,,j..,,,.___ ._,,, _, _ _ _ _ , , , . _ , _ _ _ _
6, . - . t i l *. *; . i 'i e :a:::reas , sta-: n; air valvt assy. e "e.
- e: ;r . sa: . . . , .. .. .. .. -. . ..... .
e Grand Gulf
- 2.*.! Ei e 1:ss :f s artin; air (5 =tr.utes: e T:* re::::er.:s -es 3: r;
. e sensing line not seis=ically : rift:e r :*.ne: : wn
- s.ca qualified -ire : 53 eine es .:
- era :r a:-icr. : is:*.a a line o .
e
" /*":r-i
" ~~ e sheared belts , rear cra*.hshaf: e 70I sai: vibra-icr. c;n :
cover firing f -sar :y'i n-e Grand G.if, 2* h . es r:r. e :::n=en en: tes I sn;ae: : in:r::..a:n vibra-i:r a swi c..e: : hipr.e- ren;:n (5 ,;;* :s t ) ci ::r s en'.
- i ts -
e fatiere :f 50,00C :si ::i s nea exce: ed e P.: U. now : sing 150.02: :si ality s eel b:*.:s , wi n ;r:;er hea- -estment re::r: 12/c;;Ei e g: verr.:r lebe oil cooler assy.
- e .7:I rec: : ends icwer ::un-ing e air ra;;st in linet i :1-ter
. e i=sr:;er ==ur.:ing location
- 1/05/i; i pis::n crown separa ed fr:s shir; e 701 cesti r :han;e: :
e f atiure of a- ach=ent sted b:1 s ietiev'M e wasners (Servi:n e improperly efgd. spnerical washers Infc. i; ens ;;c. 32 *: e 701 says de:ris duris; asse bi;.
~
e cylin:er liner gre:ving or ini-tal star u: e grooving of erankshaft bearini e TDI says " transient mat'1'." crank pin discolored in luce oil e cylinder link red wrist pin grooved e TDI says bieckage of iube cil,
- and pitted; wris pin cis colored ' f: reign ma :er in le:s eii e Grand Gulf
'0 /11/53 e fire-lute cil spray a cracked ins r. line e vi:ra-ion e SC::GS-i I
- g. . . .
1 . . I/31/ i'. e ust cf n n-cga*.' #it: ::crs a .?.; ,: - g , 3rge.: q,' gt.. e auA. lu:t cil ;uSO, aux. ja cr.t: 73: 13:g: :,. . wa *.t r pu.~; e T3I sus:iiec c:terical gra:t :: :rs wi-h "e:uivale..:y" .s. Ciass II m : rs
- e Equivaiency data retracted 12/15/E;; e Turbocharger iume cit sys. e ces ; gn =::ci t t :a -i c., :: :e -mi -
e luce drains oc :f nrust bearir.gs grt-l e:S f:r es s ar s i . during standby ::eration . e o:cassicnal "fas s ar 1" e :auses ex:essive wear . a:ce::abit e .e, ,. . . . .s.. a - i O 4 e I g i 1 - k ? e I l i I l l l t . m L .
_,,;*- 1. - ENCLO5URE ' 3
.r"*p...
- g. ,,t,. UNITa3 sTATas
- - .p.- ,
& .,3 , .NUOLEAR REGULATORY COMMISSIOtJ ibj l wasamcion. m. c. zossa M 'tM ! .
\ .'.' .$ # ' 8 SE. 2 i 1933
. Docket Nc.: 50-322
'7:LICANT: Long Island Lighting Ccmpany FACILITY: Shoreham Nuclear Power Station ,
SUEJECT:' SU. MARY OF SEPTEMBER 2, 1963 EMERGENCY DIESEL GENERATOR MEITING n Sectaeter 2,15E3, a team cc= posed of NRC staff :s:cers from tne Offica cf Nuclear Reactor Regulation and from the Region I office, and NRC contractors, met with representatives of the Long Island Lignting Comoany (LILCO) to discuss LILCO's- plans to investigate the cause of the failure of ' the #102 Emergency Diesel Generator at.Shoreham. A list of attendees is enclosed (Enclosure 1). On August 12, 1983, during a load test, the main crankshaft of the !102 EDG failed. Subsecuent inspection of the !101 and !103 EDG crankshafts revealed cracks in locations similar to that of the break in the #102 crankshaft. An investigation of the cause of causes cf the failure is underway and will
- be concucted in accordance with a master plan (Enclosure 2) which generally describes the steps to be taken. LILCO intends to use the resourcas of apprceriate LILCO organizations, Transamerica Delaval (TDI), Stone & -
Wetster Engineering Corporation, and appropriate contractors to carry ,'
- cut the steps outlined in the master plan. Failure Analysis. Associates-(FAA)
! will conduct the investigation to determine the cause of the crankshaft failure and the cracks. Mr. Yeungling cascribed the various phases of the program, wnien incluce l an independent review of the crankshaf t torsional design by FAA, an overall l ' design review of the entire EDG, and a review of other crankshaft failures. He reported that FAA's torsional analysis results, to date, agreed very L closcly with both the TDI torsional analysis and with the values. measured - i, by TDI in a torsional test run on the (101 EDG at the TOI factory. LILCO i
, has ' decided -to use the #101 EDG as a test-bed to gather additional torsional test information ano was in the process of instrumenting the machine at the -
time -of this meeting. The test data will be used- to verify analytical models
.ane to try to ccrrelate the observed ' problems with the effects of previous *
.< EDG qualificatien testing. l I l
.g .
- 2-Mercers of the NRC staff discussed some of the philese:hy behind the E03 test recuiremer.ts contained in the Regulatory Guides, and explained the need to understood the potential generic implications of inese failures. The staff is cencerned that the failures may indicate a deficiency in the TDI design recess which may show up in other TDI diesel generaters in other nuclear power plants. The staff then presented LILCO with a list of questiens and concerns which must De addressed before the staff can have con'idence in the ability of the diesel generators (Enclosure 3). LILCO was requested to
! respond to these items as qu'ickly as possible, as the necessary infor=ation
' becomes available, and Mr. Youngling'and Mr. Museler assured that that could be done.
Mr. Museler reported that TDI had comr.itted to pr: vide LILCO with all the sue:or necessary te solve this problem. He also ex:iainec that F'A would ha - a aam leader and that it had been instructed consider all pcssible failure causes. mechanisims and root causes, and not arbitrari'y dismiss unlikely i Mr. Dynner and Mr. Christensen, representing Suffolk County, asked several
- questions concerning the design of the machine which LILCO promised to ' answer, and were assured that they would be prom;tly notified of tne r2sul s of the inspections. The staff concluded that LILCO's plen appeared to be basically sound and proceeding in the right direction.
h. 7l/ V.NM Ralph aruso. Project Manager - Licen ing Eranca No. 2 Division of Licensing
Enclosures:
As stated . ec: See next page ' e 49 9 H e
?'; .; .
t Shorenam w.r . :d.. 'S. 8ollock Vice President - Nuclear Leng
- sland Lighting Company 175 East Old Count y Road .
Micksv111e, New York 11801 cc. Haward L. Blau, Esquire , MHS Technical Associates Blau and Cohn, PC. 1723 Hamilton Avenue, Suite K 217 Newbridge Road San Jcse, California 95125 Hicksville, New York 11801 Stechen Latham, Escuire , Mr. Jay Dunkleber.sr Twemey, Latham & Shea New York State Energy Office Post Office Box 398 Agency Builcing 2 33 West Second Street Emoire State Plaza Riverhead, New York 11901 Albany, New York 12223 Jonathan D. Feinoerg, Escuire Energy Research Group, Inc. New York State 400-1 Totten Pond Road Dept. of Public Service Waltham, Massachusetts 02154 Three Empire State Plaza Albany, New York 12223 Mr. Jeff Smith - Shoreham Nuclear Power Station Ezra I. Bialik, Esquire , Post Office Sex 618 . Assistant Attorr.ey General Wading River, New York 11732 Environmental Protaction ~3ureau New York State Department of Law W. Taylor Reveley, III, Esquire 2 World Trade Center l Hunton & Williams .New York, New York 10047 - Post Office Box 1535 Richmend, Virginia 23212 - Resident Inspector Shoreham NPS, U.S. NRC Ralph Shapiro, Esquire Post Office Box 5 Cammer & Shapiro Pocky Point, New York 11778 9 East 40th Street New York, New York 10016 Herbert H. Brown, Esquire Kirkpatrick, Lockhart, Hill, Mr. Brian McCaff r.ey Christopher & Phillips Long,I ..and Lighting Company 1900 M Street, N.W. 175 E. Old Country Road Washington, D.C. 20036 Hicksville, New York 11801 Lawrence Coe Lanpher, Escuire Honorable Peter Cohaian Kirkpatrick , LockharS, Hill , Suffolk. County Executive Christopher & Phillips
- County Executive / Legislative 81dg. 1900 'M Street, N.W.
Veteran's Mecerial Highway Washington, D.C. 20026 l Hauopauge, New York 11788 Karla J. Letsche, Escuire David Glimartin, Escuire Kirt;atrick , Lockhart, Hill , Suffolk County Att rney Christe:her & Philli;s County E.tecutive/ Legislative 31cg. 1900 M Street, N.W. Veteran's Memorial Hign=4y Wasnington, D.C. 20026 Haucpauge, New Yort 11788 . 1 .-
L t . Shoreham .. James B. Dougherty, Esc. 3045 Porter Street Washington, D. C. 20003 .
.ur. James Rivello 71ar.t Manager .
Shoreham Nuclear Power Station P. O. B~ox 623 - Wading River . New York 11792
~
Lawrence Brenner, Esq.
*c=inistrative Judge A cmic Safety & Licensing Board ,
U. S. Nuclear Regulatory Cc= mission
'Jashington, D. C. 20555
- Dr. George A. Ferguson School of Engineering P.cward University
- 2300 - 6th Street, NW .
Washington, D. C. 20059 Dr. Peter A. Morris Ac=inistritive Judge Atesic Safety & Licensing Board U. S. Nucitar Regulatory Cc=sission . Washington, D. C. 20555
s '
.t ARENDA:CE LIST Sectemeer 2. 1923
_RC
. Caruso icbert J. Giardina -
Charles Petrone
, J. C. Higgins J. T. Beard D. J. Vito
'!LCO
* .-ar. Os rowski E. .:. Yeungling W. J. Museler Kenneth Simes Franklin Research Center R. Clyde Herrick Harry W. Raines Shalid Ahmed - -
t:ewsday Stuart Diamond KLMC7 - Ceunsel fer Suffek County Alan Roy Dynner Stanley Christensen Hunt:n & Williams Anthony F. Earley e bi- ' - m. __.__ __
- Enciosure 2
- A --
Shereham Nuclea: ? a: Stati== .. Imerge.cy Diese: Generate 10: Crankshaf Failure A.alysis/ Recovery Master Plan a
!- Approvals: -
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?:c*tec- Eng;;ee: PL M*nw u
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se w ,-d 4 C.pesa:1cnal
,s j Qual;;y Assurance Eng:nas: ..
'Ig Ap ,
1 A 4 5 a:sup;ixanage:f' Q - o j->> m rH( C..as. San JC'h%# Inst GrQup L -
.L l' AA Phs=1 Manage:
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/ i h4 )'n' /WY..
Nd V:ce 7:ss:ces- Nuclear . .4 e Os:cd: Augus- ~;, 1953 ,
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- .: .: . . 3 - 1. r : 7 5. . .' .:.I M .- :* : '
t . r- - - s , : The purp se of this = aster plan is se describe the c gani a-ica and c ganizaticnal resp:nsibilities fe:
. i=ple=en:ing -he investigation into and rec =verv f c= the
=rankshaf: failure on the I=argency Diesel Gene'rate 102 a- the sh::aha= Nuclea: Power 5:atien. This = aster =lan includes a description of these activities associa:s'd with the failure, analysis; the disasse=bly of -he E=ergenev ~
riesel Genera::: := allev fer the investiga:L n =f :..e failed c==p==ents; the review cf the i= plica:icns =f this failure en the reliability ef the other two diesel
- eene at
- :s v101 and *1:2; and the identifica icn cf inquired re:esting o ensure reliable diesel genern ==
cperatien following repairs.
- =us: he a=phasized tha: the = aster plan is necessarily preli=inary in nature. F.evisicas to the approach will be
=ade, if necessary, as infer =a:Lon.is chtained during the :
acti=ns se: out in this plan. This =asta: plan has been put in place by the c:gani:ati:n ! des::ibed herein, has been reviewed by representatives ' I I LILO: 7:cject Ingineering, LI*CC 5:ar up, the Shereha: Jcin: Tes: Grcup, operational Quality Assurance.and the
- Vice-President of Nuclear. In addition, this plan has i
heen devnicped with the assistance of TransA= erica DeLaval i i
.Inc. of cakland, Califernia and Tailure Analysis '
Asse:iates of Pale Alto, California. i II. ORGANI:ATICN: As a result of t'he failc:a of the ::a..kshaf: :n i I=argency Cissel Generate: 102, an organization has
- heen put in place consisting of the necessary i expertise to assess -he cause or causes of the crankshaft failure; to recover fre= that failure and perfer= suitable estesting f olleving recovery and te
. deter =ine the implications of this failure en diesel' genera:::s 101 and 103. The essential areas of enper-ise.are shewn in Attachmen No. 1 0:gani:ati:nal
- n e: face Diagra= and c=nsis of -he felicwings a.
^
5:artup Persennel
- . Ingineering Fe:scnnal
- . Scheduling Fensenne*
- f. Vend:: Kapresentatives (TDI) b
i 1
., 't .
.i -
.. Plans. Staff Maintenance Supp::: Persennel
- f. Tallure. Analysis Censul: ants
- g. eparational cuali:y Assurance and 03: CA Ps:senne' .
t In additics to the organizati:n shcun en the attach =ent, suppert from the LILCO office of Nuclear . as well as -he an.: ire Lcng Island Lighting Censane a:s available, such as the Purchasing, Ingineering', Maintenance 3ervices and Quality Assurance Depart =ents. - A. L LOO Startus - L L;;;c startup under the dire::icn cf the Startup
- . Manage has the primary line resp:nsibility f::
i=ple=enting and scheduling the entire effs : == the three diesel engines since the I=s gency Diesel i Genera ces are still under startup jurisdicti:n. i , Repair Rewc k Pequests initiated by Test Infineers will he the base doc =ent for the rework vish
- Main enan=e Werk Requests (MWP.' s ) being used to zu : pert ad-4=istrative requirements of the maintenance
, cc.:: actor, Catalytic Inc. and othe =aintenance ( , supp=== c:ganizaticas. I=p1,ementing' maintenance and - te,st procedures will be gene a:ed by Pr=je:: - L Ingineering, startup and TD and will be p:cvided :: L the field via the aheve base documents. 1 [ g
,, ' .p .% = s.swe y *.w%e = *
- s= y g
ca:alyu : In:., a supple = ental maintenan=a c::::a ::: to the LILCO Plan Staff maintenance se:-ica, will prepara the. equipment for re=cval of diesel generate: 102 from the Diesel Generater 7.cc= by discennecting . the piping, electrical and other appropriate c=nnections to the engine and ganara:c: in acec dance with Oiesel Generate: 102 Dis ==nne::icn Chech*ist and
.i=ple.menting work reques: documents. i l Geresa Inc. , a rigging and hauling cent: 3ctor, will
- jack and skid the diesel engine cu
- of the roca and l transport the uguipmen to the Turbine Building l..
turbine de:k, Ilevation 63'. TransAmerica DeLaval Inc. (ODI) , the diesri engine
=anufac:::er, will perf := the dissssembly and i rebGilding of the engine. Additionally, the generate:
will be inspected under the c gna:Ance =f its ! manufa:-u:e: (7:::e:) :o deter =Lna if is sustained any damage. . , =
, _ - . - - , , - , . . , _ , . , . . , , , , , , , - - . . . , ,.-,..,~ ,.,~___,.. m -. -,, - ,,..,__,,.,.,.e,_~,--.mw,,~.--....,..-.--,,.
.s
- representati'ses vill c':sarve all a=:ivities ass ==ia:ed vi-n -his inve stiga:ic: and vil; p:': vide achnical dire::icn. 70; v 11 p cvide regetred rep; ace =en: parts.
C. L;100 ? cie : Incineerine- . L ;c: 7:=;ec: Ingines: ng (LPC) assisted by the 5::ne
& Webster site Infineering Cffice (SIC) vill p:cvife engineering suppers and is resp:nsible'fer the fai;ure analysis. Tc a=c==plish -hase tasks L?C will use is own rescurces supplemented by 5:ene & Webste:
i Ingineering Ccrporation, TO , Failure Analysis Ass ==is:ss and c-her c ssultants as required. Tailure Analysis Associates has been charged :: take whatever steps are neesssary := deter =ine the cause c: causes cf the failure. D. Cuality Assurance Cperatzenal Qua11:y Assurance will pr= vide the required Quality Assurance'ceverage in ac c dance with the "ILCO Quality Assurance P:cg :=. TDI CA , representatives will be presen during the period cf engine disasss=bly and reassambly by the TO: work force. The LILCO Quality Assurance Depar =ent will ,
, p : vide supper: se -Jun CCA c gani stien fer quality 1
assurance =a :ers. I. shift Cc=elir.en: Dur ng sa s investiga:icn and the schsequent recevery l
-he en shift c:=pliment will c:n, sis cf the felieving:
l
. Startup Test Engineer .
! Engineering Kapresentative
,TDI Representative Tailure Analysis Associates Representative CGA Representative
- '.zintenance Supper: Supervisc:
The Tes: Ingineer will be the Shift Direc c and is responsible for i=ple=enting the activities designated ! to be acccmplished during that shift. A pre shift meeting will be held to insure p:cper coverage is - available and to .eviev thess activities with the shif c:=pline.:.' T. 5:ce Work Autherity na su:n=:::y := "!TCP WC?.F" based c.. :he CA l CCA nas nanual. 1' Ps:suan: to the nemeranda f:cm the 5:artup ::anager, A::ach=en: 82 and 83 the en shif: TAA reprere..ta-tve and 70: rep;ssen a:ive nave been c.uthert:ed te s:c; ' wc h th = ugh -he Tes: In gi:.e e r . 3 I v
h k 3e%+ftg+f@c/ s IMAGE EVALUATION TEST TARGET (MT-3) ((//gfNTp# g f +4,#4 g+ ,q,ff > q,,q[q
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The evera*.1 werk effort vill be under the review and a __ ' _' . c .' ..' . e .~ .~ _'. . . '. e s . G _- "_ . a s ' e s ~. .~ _'. ". e ^ .'. . .%.. e Sherena: Startup Manual. r_',
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. Cc=ca: an :.nvestiga:icn of, and develop a detailed failure. analysis fer the Diesel Genera:=r 102 I cra..hshad: -
- = de:e.=ine causes for failure. This l
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- 2) A=.=. :=.riate analysis of the failed crankshaft.
- 3) 7.sview saintenance and operational history.
- 3. Crankshaf: Desich Concuct an :.nspectien. and assessment cf the adecuaev #
- of the existing (13" x 11") and replacement (13 x 12") TransAmerica DeLaval Crank Shafts for Diesel Genera:crs 101, 102 and 103. This effer censists cf .
a the .o,a.cwing: 11 7.eview of the TDI design cal =ulati:ns.
- 2) Perf===ance of-independen: calcula:ic=s, as res: ired.
- 3) Perfer=ance of operational tersicnal vibration tes:s at varicus s: ends and e=e.ine Icads e . the.
existine. 12" x 11" crankshaf s in diesel-genera crs 101 and 103 and on the replace =ent 13" x 12" crankshaft for diesel-o.enerator 102.
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A. Inscectiens & Tests - Diesel Genera:cr 102 Tne inspections and tests on diesea generate: 102 include but =av. not be limited to the following: 1.1 The ::nne= tine. rod 'er ev.linder no. 7 will be
.- mul'ed to allcw for inspection / examination f :
. .,.,z._.,._
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2.1 "
..ain ' bearings #E, 9, 10 & 11 afd.a an to the fail :e v 11 he pulled c inspect f:: da= age ::
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. . __ t. h. . .'. s Vi'.1 he perfcfmed as soon as pcssible te allcw evaluatica cf damage.
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y = ..e . a .. . ..sy.----.. . NCTI: !:e= 1 and 2 abeve te be a==== lishgi prie: .= rencving the diesel genera: h fr== -;.e ) roCM. 1 1 I
- 3. Insee=:ica and Tests - Diesel Generator 101 and 103 ;. and Tne ngpe : ens anc tests en diese- genera:::
3 n. :, 4 n c a. t..a. e s.A .. ga.. . n-.-- - bg -- i4=4- - g a -.. . k. e .4 ..--. t i J-.. . ,. ,.-. 1.) 100% visua'. inspecticn of ::a..kshaf t ve:s and dye menstran tests where apprcpriate. . . :/ , . uI
. 2) the conne=:ing reds : . cylinder 6 ".--s-s-TIll be
=clled te perfor= 100% LF and UT cf the -
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C. Diesel Generator 102 Reverk LII,co nas everall resp .simility for the Diesel Generater 102 rework effort. The Startup Test Ingineer en shift will supervise the varicus aspects of the werk describec below. Catalytic persennel will remove pipe, unbing'and electrical c=nnections, disconnec: the turbecharger; and discennect the generater in preparatien for i.ncking and skidding the engine cut of he roc =. Garcsa persennel will rig;-and jack the engine, skid it-e..- . n a -ecma
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. turbine building truck bay. The entire engine will =e lifted via the turbine. buildine. crane and se inside .. .
an existin cac.,ed-in area on n.e sure ne bull 2:.- .n e. deck. A clean room will be set up and access control will be es :blished. TDI personnel will perfer= the disassembly all:wid; the a=.= ret.riate insm.ecticas to take place. The TDI I Service .:.euresentative will be the ress.ensible superviser for the TDI workman. The genera =r will i also be inse.ected for da=ac.e while en the turbine I - deck. LII.CO and TAA inspections will be perdermed -
'd"- ' .2 , u..s we-k. .
l Cnce re=cved, the damaced shaft will be sent eff site - i
- i. fer failure a .alv. sis .
T :ersennel will re:uild the engine under the supar.is:.cn of a TO: Service ..eprese. ative and es
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- a. All ce=penents disturbed by the rewcrk will be subjacted := appropriate C&IC, includin- calibra:icns, elec rical wire che=hs, and pneumatic unbing
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f , . Ou . .g the investigation cf the Diesel Generate: 102 fail :e the duly authorized . Tailure Analysis Assceiate Representative as .$.e s. c ... 3..,. 4_ ., .. ... a s ...'s a.*.'..e d .v. .c s .o. i wo f". as ...., '
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t This s: p w= k authori2ation is being given to insure tha: the Tailure 7nalysis Associa:es people are in a p=sitic: to c ..s.._a- _,. ._ -.,,y e ,. . ,, ...g 4 ..ium .4..a.."- .. a ._i o.n .* - :n ..'.e " a _d. ' u_ a _a .. ..es.. , : a..a . . ~ . Upon issuing a s =p work order -he rail.. e .,..alysis Ass:ciate . sopresentative shall notify the undersigned of this action i _d . . ad'a aiv.. _ i i . WW '
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l Enclosure 3 Infer =ati:n F.ecuests en Diesel Ge.e a : t ID/Gsl I. Generai a
- 1. Provide a written summary of the approach to be used on the Failure analysis for DG 102 on an expedited basis.
- 2. Provide the preoperational NDE records of the three DG crankshafts.
- 2. Provide the number of crankshaft failures and peculation size for all Delaval D/Gs, all nuclear service Delaval D/Gs, and all R-4 D/Gs.
l . Provice the failure analysis, if any, for the abcve crankshaft failures.
- 5. sr:. ice the to:al nu= der of operating hours en each D/G and the :: ti 4
nu= er of hours at 3900 KW or greater.
- 5. Provide copies of all LILCD/5&W audits of Delaval and responses.
7.1 What is the maximum load to which these D/Gs c:uld be upgraded?
- 7.2 What modifications would be required to make the upgrade?
7.2 Wh,at are the limiting co=ponents? . T 7.4 Provide an e'rly a reply as to whether these three eses:icns can be ar.swered and an estimate as to when. * *
- 8. Provide an explanation of the claim in the June 10,19E2 letter of Delaval to LILCD that t,5e LILCD DGs are " state cf the art" with no other product improvements which could positively affect reliability in light of the subcover cracks and crankshaft failure and the fact that modified parts were available but not identified. Also prrvide a cm:nitment to review all product improvements available for the Shoreham D/Gs, if these D/Gs are to be reoaired and used.
- g. Dees Delaval have a program where parts /cc=::.*ents etc. are modified (such as design margins reduced) in order to improve Does this apply to any D/G parts for Shoreha=? Oi.. . . yjj L, /
- 10. Previde responses te all NRC open items on D/Gs.
- 11. provide responses to all items in NRC consultants's report.
- 12. Provice all vencor decumentation en crankshafts, certificati:ns of c:nfone.ance, s:ecs, f:CE records, etc. Include sta:ements of how and w..ere fr:= each crank thaft criginated.
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"* 'POV!Ce j: s-ifjcatica f r grindia: cracks - -e 1
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ainure annoysts . yefere en! Sribding is ne ? 1-14 Provide a coc=ittment e*or * :t 9t demonstra e adequa e vibra-ion after reinstallation.
- 15. F.es:ense to 5/12/82 Delaval Par ** '~1. repor, en 3 arting air valve
, . ass esly. O O S J O D F e S e p 9 G e
n n - l!. Prec:remer.: *
- 1. Provide precurement specifications to which the diesel generators were
. ordered. In addition, provide the performance specification; and the inspecticas performed upon receiving the diesels to shew that the
. procurement specifications were met.
- 2. Discuss all tests perforned on the DG's that were observed by LILCo at tne manufacturing facilities. Describe all the tests performed at the manufacturing facilities that were not observed by LILCo. The description shculd incluce test procecures, pertinent instrumentation diagrams, and test data and results.
~
- 2. !n acdition to the cualification tests pefernac in accorcance with the guicalines RG's 1.9 and 1.103 and IEEE Stancarc E37, cascrise all onsite tests that were performed on the DGs. Provide test procedures for these tests and also the data and tests results.
4 In addition to the deficiency reports alrency provided to the NRC, describe any installation problems encountered during the installation and operation of the DGs. Provide complete operating histories of tne DGs.
- 5. Provide a ' description of the original design basis of the straight eight DGs used at Shoreham and a ecmplete and detailed list of all product improvements made in this product line of DGs. Include in the description the racemmended continuous and maximum loads and the operating hours for each rating for each modification.
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- 6. Provide a latest ccpy of the technical instruction manual for these DGs.
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!!! . Condi-ic..s of -he s tiu-e C::urance .
I
.. pr:vice t. a :es prececu as that were :ef n; used a ..a ti. a cf .9e failure.
- 2. Describe tr.a cenditiens in the test area prior to, during, and after t..e failure. The description should include all pertinent test ir.f: ma-ice,
' vital signs, and test ccndi-ions such as test grid condition, all i..strument reading prior to failure ano post-failure, dither, all races, vtbra-icns noticed and recorded, and noises.
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- 1. Provice a copy of the Failure Analysis Associates (FAA) cnarter.
- 2. provide the manufacturer's design calculations fer the tersional analysis of the DGs. In addition, provide the models used, metnods of arriving at the lu= ped otra:eters, justifications of any correlating factors used, calculations of all the natural frequencies, their = ode shapes including the mode locations. '
- 3. Cestribe all the torsional testing that was perfereed by the manufact-urers on the straight-sight DGs. The cascription sheuld include the test procedure, test data, test results, ccnfiguratiuns and cecoonents cf the D3s and Icacing devices during the test, and the instru=entation used and their locaticns.
4 Compare the DGs presently at Shorenam with all either TDI amargency DGs models now in use or to be used in other nuclear generating stations to show that the conditions and/or failure modes present at Shoreham will not occur at these other nuclear plants.
- 5. Describe the analytical investigations that FAA is or will be performing on'the DGs. The description shall include the torsional vibration analysis, the stress analysis and the evaluation cf the TDI torsional vibration and stress analysis. . ,
- 6. Describe' all the testing that will be perfor:ed by F'AA on the emergency DGs at Shoreham. The description shall include test procedures and objectives, instrumentation and location, test data, test results, tast loadings, test configuration, power factors, and methods of evaluation 1 cad interactien. .
- 7. Based on the results of the analytical investigations and the test resu'.ts, describe the effects. -if any, that fast starts had on the fa11ure.
E. Describe all the metallurgical and failure analysis of the cranksnaft that will be performed by FAA. - i I I 1 l [
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. *tscribe any new Cr a:ditiCna' 05: lems Or casi ri Officiencies t.".at ma"y c::ur as a result cf the installation of -Jie IEx.2 :rankshaf t.
- 2. Describe and justify the requalification testing program'that wil* os performed.on the modified cgs. The descriptien snail include to-sice.al vi: ration and stress testing, any testing,in acdttion to the testing required in RGs 1.9 and 1.108 and IEEE Standare 357.
3 Describe the impac1, of the previous multiplicity of failures on the modified DGs. , G 9 e e O O 9
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- VI Ree:-Cause Analysis
- 1. Fr: vide a r :t-cause analysis which shows that tne varicus failures
- u=ented in varicus deficiency reports and other cccumentatiens are ne: causally linked; fer exarncle,could c: cling .a:er leakage c:ntributa to crankshaft failure?
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j , e E[*::LOSURT 4 s 55 INS No.: 5235 IN E2-51
. UNITED STATES NUCLEAR REGULATORY COMMISSION
- OFFICE OF II.5PECTION AND ENFORCEMENT WASHINGTON, D.C. 20!!!
August 5, 1983 IE INFORMATION NOTICE NO. 83-51: DIESEL GENERATOR EVENTS Addressees:. All nuclear power facilities holding an operating license (0L) or a construction
- e mit (C?).
Pur::se: ,
~
This infomation notice is provided to bring to the attention of licensees and construction permit holders some events and experience of generic diesel generator problems and corrective action taken. It is expected that recipients will review the infomation for applicability to their facilities. Nc cther action or response is required. - Description of Circumstances: i In its continuing review of licensee' event reports (Lens) NRC has identified during the past five months more than 100 LERs pertaining to diesel generator problems. Most of these appear to be meterial, equipment, or component failures., No single ecInman trend can be identified. , NRC is cencerned' about the large number of diesel generator events. During discussions with diesel manufacturers and licensees, it appears that many of these. events could have been eliminated or provented by implementation of a conscientious maintenance and inspection program as well as monitoring equip-ment thrcugh a plant's trend program. Some 1.icensees have instituted such a pregram to detemine the underlying cause of the failures (see IE Information Notice 82-10) and to prevent their recurrence. Components or materials that have experienced failures are monitored or inspected more frequently. Many - affected items are repaired or replaced before actual breakoown. For example, '
- cooling water heat exchangers that were found to be ineffective af ter a certain
[ period of time because of tube fouling were replaced. Cooling jacket circulating water pumo bearings are inspected for wear and replaced i.n certain intervals. Pressure switches and timers have' been found with drif ting setpoints and werr
- recalibrated or replaced frequently, Eecause of the large number of diesel generator events it is not feasible to
- ssertee all tne events re::rted. Hewever, Attacnment 1 to this infcmatien l :tice gives several representative exa.mples and corre:tive actions taksr..
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II; 53-51' August 5, 1952 Page Z cf 2 If ..e-e sre any cuestiens regarding this matter, ; tase c:ntact ne Regicnal Ac=tr.istrator of the appropriate NRC Regional Office, or this office. _Y' N. ** Edward L. Jorda Director. ! # Division of Emergency Preparednes and Engineering Response . Office of Inspection and Enfordement Tec..nical
Contact:
Wolfgang Laudan, !! 301-492-9759 . Attaen=ents:
- 1. Selected Examples of Licensee Event Reports Related to Emergency Diesel Generators
- 2. List of Recently Issued IE Information Notices f.
4 9 f. e l s O " A
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,, At ach e.: 1 j IN E3-!;
, August 5, 19E3 Page 1 cf a SELECTED EXAM.:' E5 0F LICENSEE EVENT REPORTS AND VENDOR REPORTS RELATED TO EMERGENCY DIESEL GENERATORS -
OUAJ-C* TIES 2. CCTOBER 5, 1952 - During the monthly preventive maintenance testing of Unit 2 diesel generator, the diesel tripped on high temperature 10 minutes after loading. The cause was deterinined to be fouling in the cooling water. heat exchanger. The heat exchanger was replaced.and the diesel testing was satisfactorily comoleted. The licensee olaced the heat exchanger on a preventive maintenance schedule for cleaning,. SECC0YAH 2, OCTOBER 20, 1962 During a performance test of diesel generator 25-5, the cooling jacket circulating water pume on the diesel generator was found to be inoperable as a result of a ball bearing failure in the pump. The bearing was replaced and the diesel generator was returned to service. SUSOUEHANNA, CCTOSER 27, 1982 ' I During a performance test of a diesel generator, the diesel generator tripped on high vibration. It was postulated that a vibration switch and a pressure regulator were both involved in the trip. Both were repaired and the df esel generator was returned to service. The equipment will be monitored through the plant's trend program.
- ERUNSWICX 1, NOVE*SER 5, 1982 During a cuick start testing program of diesel generator No. 4, the diesel generator tripped. on "lew lube oil pressure." The same problem occurred 2 days later en the same unit. Both events resulted from intermittent failures of.the " low lube oil pressure start time relay" (STR). The relay timed out before ac ual pressure was above the low trip setpoint. The relay was replaced and the diesel testing was satisfactorily completed. , ,
DRE5 DEN 3, NOVEMBER 9, 1982 During a Unit 3 diesel generator surveillance test, the diesel generator tripoed or. low cooling water pressure. A defective' low cooling water pressure switch caused this event. The switch was replaced and the testing was satisfactorily cemcleted.
- .'; Cwt !!CO. MAY 25. 1gE3 During startup testing, the oiesel generator would not reach full cpersting spesd. The Woodward governor speed adjustment on the unit stepped at at: cut
(!O' rpm. It was found that the pointer disk was har.ging up behind the cial plate. The manufacturer recc= ended filing about 1/15-inch off the pointer disk to allew free movement. After that the diesel achieved proper speed.
I 4 - Attach.en- 1 IN E3-i'.
, August 5, 1953
, Page 2 cf a CALVERT CL:~ 5, APRIL 7, 1963 heing a ' routine inspection of the intake air check valve of No.11 dissai ge ,rator, the licenses found a check valve holding pin sheared and the check valve locse. The.same valve on two other diesel generaters at Calvert Clif fs had been found to be cracked when inspected during 1982. The disk of one of ittse .alves was found broken in two pieces. The engines in quest. ion are Fairbanks Morse Medal 387D81/8.
i 5ecause 'these failures did not render the diesel generators inoperable, as evicenced by successful c::.;ietion of weekly cperational tests, nc LIR was
; issued. The licensee pointed out that there were internal baffles between the check valves and the diesel turbochar;er whic.n made it unlikely to have a ciece i cf tr.e eneck valve enter the diesel's turoocharger. The eneck valve in questien
! diverts air between the diesel, turbocharger and integral air-blower. Failure of the check valve would result in air being available through the turbocharger at low leads and would affect the load control.
~
SHOREHAM. OCTOBER 15. 19E2: APRIL 15, 1983: APRIL 20, 1983: MAY a, 1983 During preoperational testing of Shoreham's three Transainerica Dela. val, Inc.
- ', ear,argency diesel generators, the folicwing nachanical problems were identified -
in the past i months and reported by the licensee under 10 CFR 50.55 (e): l October 15, 1982 -Thejacketwaterpumpshaftfailed$
. April 15,1983 - The engine head cracked.
- April 20, 1983 - The, fuel injecticn line failed. ,
l May 4, 1983 - The rocker ann bolt failed.
- Approximately 2 years before these problems occurred, the licensee discovered the following
- 1. Loose hardware in cam gears during initial onsite inspection.
- 2. P.ultiple broken cylincer head exhaust bolts resulting from insufficient i pipe guide clearances in the exhaust manifold.
- 3. Cracks in the fuel oil ejector that connects to the fuel oil drip line.
- a. Absence of a drilled passageway for the relief valse on one lube oil pump line as required by design.
- 5. Leaky lube oil cooler tubes resulting from improper rolliag in the tube i sheet.
l 6. Cracks in rocker arm push rod sccket (or cup). ! 7 .. Cam gear fitted bolts not installed at the factory as required.
~ha :recis .s were c:rrectic under the surveillance of vender re:resentatives.
'sucitar sites witn Transa erica Delasal diesel generaters are listec en
- age a of tnis attachment. .
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. IN 83-!!
August 5, *523 Page 2 cf I. LOUIS ALLIS REPORTED TWO DIFFERENT POTENTIAL PROELEMS. MAY 20. 1983 . (Louis Allis is the successor to Belouit Power Systems, Inc., and to Coit-Fa !.-banks Engine Division) ,
- 1. At the diesel generator in the Clinton Nuclear Plant, a three-chase rectifier assembly in the exciter was not connected in parallel, which could cause field winding insulation to deteriorate. Louis Allis field service took corrective action by making the necessary connections.
4
- 2. Detroit Edisen excerienced high vibration on its diesel generator. The cause was loose pole wedges. Louis Allis pe der ed a oetailee enginte-ing e.,alua-icn of this preolem and founo that in 1- i a material change 'r:n HRS 1020 steel to 1045 steel was made. This means that diesel generators manufactured before this ' change may experience the same loose pole wedge problem. The affected plants are Femi, Millstone Unit 2, and Hatch.
These, plants were notified by copy of the Part 21 report dated May 20, 1983. . TRANSAMERICA DELAVAL - 1981 TO 1983
- 4 .
' ,_ The manufacturer reported the following turbocharger nrust bearing lubrication problem: ~
The design of the lubricating oil system permits the oil flow to the turbo-charger bearing only when the diesel generator is running. When the diesel generator is in the standby mode, the turbecharger ben. ring lube oil system is bypassed to prevent a possible fire hatard should pressurized oil leak around the bearing seals ento hot impe11ers. Therefore, during startup, a sufficient amount of oil would not be available to adequately lubricate the turbocharger bearing. Secausa diesels are. started once a month and run for a short long-h t cf time, premature bearing wear was experienced because of insufficient lubrication. At San Onofre, the wear rate for thir condition after 100 hours of operation
' was equivalent to 15,000 to 20,000 hours of , continuous operation.
l ' l To ensure proper lubrication during startup, a design Edification in the ' form cf a lubrication oil drip system causing the lubricating oil to drip on the bearings through an crifice at a given rate was pro:: sed, installed, and tes ed. An alternate method to this design m:dification is a change in the c:eratingprocedure. Before a monthly start, an operator would manually run the auxiiiary lube oil pumo for 30 to 60 ses:nos and c:nfirm lube oil :ressure. i IP, r.t tvent of an emergency start, the estrings wil' function unti'. oi* pressure is develepec. . j r 2 e
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6 Atta:h=en: 1 IN EI-51 August 5, 15E3 Dage 4 Of 4 Tra. : steri:a Delaval reported that the following nuclear sites were affected: Shoreham Perry '4PPSS 4 . Grand Gulf' Bellefonte Midland 1 & 2 Catawba WPPSS 1 P.artsville San Onofre Comenche Peak 1 & 2 Phipps Bend Thelicenseesoftheaboveplantswerenotifiedby©ofTransamericaDelaval Part 21 resort dated Se:temmer 19, 1930. t Q e y 00 e e e
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, August 5, 15E3
- LIST OF.,8.ECE!!TLY ISSUED IE INFORMATION N,0TICE5 Inf c-: .a ticn Date of Nc: fee No., Suoject Issue Issued to 83-s0 Failure of Class 1E Safety . 8/1/83 All power reactor Related Switchgear Circuit facilities holding Breakers to Close on , Demand an OL'or CP 83-49 Samoling and Prevention cf 0.7/25/83 , All power reaetor Intrusien of Organic Chemi- facilities holding cals_Into Reactor Coolant an OL or CP Systems 82-48 Gaseous Effluent Releases 07/14/83 NRC licensed bypro-of Radioactive Iodine-125 and proouct material Iodine-131 in Excess of NRC licensees, including Limits medical and academic institutions, radio-pharmaceutical sup-pliers, and indus-
. tr,ial research I 83-47 Failure of Hydr'aulic Snubbers 07I12/83 All power reactor as a Result of Contaminated facilities hoicing Hydraulic Fluid an OL or CP 83 46 Comon-Mode Valve Failures 07/11/83 All power reactor Degrade Surry's Recirculation facilities holding Spray Subsystem an OL or CP 83-45 Environmental Qualification 07/01/83 All power reactor Test Of General Electric facilities holding i
Comoany "CR-2940" Position an OL or CP Sel'ector Control Switch .
, 83 44 Potential Damage to Redundant 07/01/83 All power reactor Safety Equipment as a Result facilities holding i
of Backflow Through the an OL or CP Equipment 83-43 Imoroper Settin 06/24/83 - All cower reactor mediate RangeIR) (gs of Inter-High facilities heicing Flux Trip !stooints an OL or CP 22-42 Reacter Mode Switch Modi- 06/Z3/83 All EWR facilities fications holding an OL or CP c:. = ".: erat;ng License CP = Ccnstruction Permit L
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Occr.et Nc. 99900334/S3-01 ,
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Transamerica Delaval, Incorporated Engine t.nd Compressor Division > ATTN: Mr. C. Mathews General Manager 550 25th Avenue Oak.iand, California 94251 Gentlemen: This refers to the inspection conducted by Mr. J. V. Sutton of this office on July 11-15,1983, of your facility at Oakland, California, associated with the manufacture of emergency diesel generators and to the discussigns of our findings with you and members of your staff at tne conclusion of the inspectic This inspection was made as a result of the issuance of several 10 CFR Parts 21 and 50.55(e) reports. The reports pertained'to: (1) incorrectly iden.ified bolt material, (2) failure of high pressure fuel cil injection lines', (3) failure of jacket water pump shafts (3) failure of a crankcase cover bolt, (4) unqualified isoprene material, and (5) deficient piston s ki rts. These conditions were cbserved singly cr in combination at one or more nuclear generating stations.
,' A eas examined and our findings are discussed in the enclosed. report. Within trese areas, the inspection consisted of an examination of pro:edures and representative records, interviews with personnel, and observations by the i.,spector.
Curing the inspection it was found that the implementation of your CA prugram failed to meet certain NRC requirements. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. This flotice of Violation is sent to you pursuant to the provisions of section 206 of the Energy Reorganization Act of 1974. You are required to
- submit to this office within 30 days from the date of this letter, a written statement 'containing: (1) a description of steps that have been or will be
.aken to correct these items; (2) a descripticn of steps
- hat have, teen er wi'.
be taken to prever.t recurrence; and (3)' the dates your ccrrective a~ctions anc
;.reventive 5.easures were er will de ecmpletec. Corsideration ay te.given te e.tancing ycur respc.nse time f er goed cause she n.
v eu are aise requestec to s tmit a similar written state ea.
. fr eacn item which appears in the enclosed fictice of tionconformance.
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T ansamerica Delaval, Incorporated 1 'l .,".1,'/ 7. ' ' * ~ I', ' '" Engine and Compres'cr s Division -b. ..w.' - * " " The responses reouested by this letter are not subject to the clearance
-cocedures of the Office of Management and Eudget as required by the ' aper crk Reduction Act of ISSO, PL 96-511.
- In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this
~
letter and the encicsed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your inten, tion to file a request for withholding; anc (b) submit within 25 cays frem the date of this letter a written applicati:n te this ef fice to withhold such information. If your receipt of this letter has been celayed such that 'less than 7 cays are available for your review, please notify inis of fice promptly so that a new due date may be estas11sned. Consistent witn Section 2.790(b)(1), any such application must be acccmpanied by an affidavit executed by~the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 C.cR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted.above, the report will be placed in the Public Decument Room. Should you have any quest' ions concerning this inspection, we will be pleased to dis, cuss them with you. Sincerely, e -
\
a.cx i Ulcis Potapovs, (nie Vendor Program Branch en . l
Enclosures:
l 1. Appendix A - Notice of Violation
- 2. Appendix 8 - Notice of Nonconformance
- 1. Appendix C - Inspection Report No. ?9900334/22-01 4 Appencix D - Irs:e'etien Data Sheets (il pages)
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APPENDIX A
- e ransamerica Delaval, Incorporated Engine anc Compressor Division -
Oceke; No. 99900324/23-01 NOTICE OF VIOLATION As a result of the insoection conducted en July 11-15, 1953 and in accercan:e ei:n Section 205 of the Energy Reorganization Act of 1974 and its implementing regulation 10 CFR Part 21, the following violation was identified and has been categorized in accordance with the NRC Enforcement Policy (10 CFR .9 art 2, Appendix C), 47 FR 9987 (March 9, 1982): Section 21.21(b)(1) of 10 CFR Part 21, dated Decer.ber 30,19S2, states, in part: A director or responsible officer subject to the regulations of this part or a designated person shall notify the Cc. mission when he obtains information reasonably indicating a failure to ecmply or a defect affecting . . . a basic component that is within his organization's responsibility and is supplied for a facility or activity within the United States that is subject to the licensing requirements under Parts 30, 40, 50, 60, 61,.70, 71, or 72 of this chapter. The above notification is not required if such individual has actual knowledge that the Ccmmission has been adequately informed of such defect or such failure to comply. Contrary to the above, a director, responsible officer, or designated cerson had not notified the Commission in regard to:
, 1. Jacket water pump shaf t f ailures on the emergency diesel generators (EOG) that had been furnished to the Shcreham Nuclear Pcwer Station.
- 2. A potential defect in the fuel injection line tubing that was used on EDGs furnished to Grand Gulf and San Oncfre.
This is a Severity Level IV violation (Sc;plement VII). . s I
~
y ... ,_. APPENDIX B Transamerica Delaval, Incorporated Engine and Compressor Division - - Decket No. 99900334/83-01 NOTICE OF NONCONFORMANCE
!ased on the results of an NRC inspection concucted on July 11-15, 1983, it a; pears th'at certain of your activities were not c:ncucted in ace:rcance with NRC recuirements as indicated below:
Criterion V of Appendix 8 to 10 CFR Part 50 states: " Activities affecting ouality shall be prescribed by documented instructions, procecures, or - drawings, of a type appropriate to the circumstances and shall be acccmplished in accordance with these instructions, procecures, or drawings. Instructions, procedures, or crawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily acco=plished." . Nonconfermances with these requirements are as followsi l l 1 Paragraph 4.E.2 of Section 4 of the Quality Assurance Manual (QAM) dated April 30, 1951, states, in part, "when required by Purchase Order material received destined to.beceme a part of the manufactured item must be . accompanied by a Certif.f cate of Vender inspection. The material is then . inspected to all applicable specifications utilizing Vancor Certifications . . . ." In addition, paragraph 4.1.1 of Quality Control Procedure 1.P.200, states, in part, "when it is determined that product deviates from specification, an Inspection Aepert, Form P-249, will be initiated by the Receiving Inspector describing the nature of the defect." Contrary to the above, the Transamerica Delaval Incorporated (101) - receiving inspector accepted material on Purchase Order No. 45333, for . which required mill test reports had not been received, without issuing a nonconformance form P-249. - E. !atparagraphs of II. A and II.E cated January 29, 1976, anc No0emper 10, 1*-69, respectively, of tne Draf ting Room Practice (ORP) recuires: (1) cra.ing of layeuts on tracing paper; ano (2) a special titie bicek on layout cravings with a ple space for signatures in full of the cesigner and witnesses along with dates.
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Cch'trary to the above, the fc11owing leye t = ravings f=r the late 1552 recesign of the emergency ciesel generator (EDG) jacket water pum; had not been (1) drawn on tracing paper and (2) signed and dated: (a) 1C1973, ' , (b) 03-426-03-AA, and (c) 03-425-10-AE (lined through). . C. Paragraphs 2.2 and 2.3 of the Engineering Operating Procedure (EOP) 4, dated April 19, 1979, states, respectively, The designer shall perform the pecessary calculations, if required, and prepare the required design layouts. .
"The designer'shall sign, date, and submit the calculations which he has checked for ccmpleteness and accuracy, alen; with the cesign layout as required, and his signed and dated form E-213, to the Manager of Design."
Paragraph II. A.6 dated January 29, 1976, of the Draf ting Room Practice, states, "Important calculations should.be written in the proper notebook, maintained in the department files." Contrary to the above, regarding calculations for redesign of defective EDG jacket water pumps located at Shoreham Nuclear Power Station:
- 1. Calculations for the first occurrence (1979) which are written in the proper notebook had not been signed and dated in the spaces provided.
. 2. Calculations for the second occurrence (1982) had not been (a) { signed, and (b) written in the proper nctabook. D. Section 6 dated February 27, 1981, of the QAM, contains the following requirements:
- 1. Paragraph 6.1.1 states, " Documents establishing and defining processes and procedures pertaining to the quality of the product shall be controlled by the subdivision that has the initial responsibility of issue."
l 2. Paragraph 6.2.1 states, in part, "All documents relating to the quality of the product shall be reviewed by the manager of the i,ssuing section or his representative."
- 3. Paragraph G.3.1 states, in part, "All documents such as (ngineering drawings . . . rust have a mechanism for icentification, av,thority of issuance and revision."
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3 l n.. ,.. .. .... .. .. .. .. .. .. . . w.. .w . . . . wms e ,wn u. s e w ~~= C:ntrary t: the above, "O Shee s" which per*.ain to cuality of the crecu:t are issuec by the Engineering Department; no ever, they are not reviewed by the =anager as evidenced by the lack of provisions to identify the date, preparer, reviewer, approver, or revision. Examples e are D-4986 and D-4956, which are entitled, " Assembly Instructions " anc pertain to the EDG jacket water pump. It was noted that the latter document reflected the release date, four revision levels and dates in the lower margin of the affected sheets. E. Paragraphs 5.3~.2 and 5.3.3 of Section 5 dated February 27, 1981, of the QAM, require that Manuf acturing Engineering provide written instructions in the form of r:ute sheets', tooling sheets, or special written instructions, etc., to Manufacturing and Assembly Departments. Paragraph 16.2.1 of Section 16 dated February 27, 1982, of the QAM states, in part, " Manufacturing and assembly Route Sheets are used as records of in process inspection of parts, components, and assemblies. All Route Sheits are retained by Quality Control as objective evidence of inspection acceptance." Contrary to the above, route s'heets for the assembly of the EDG jacket water pump reflected on Drawing No. 101973, Revision C, had not been retained by Quality Control at objective evidence of inspection ecceptance. ! F. Paragraphs 2.4.1 and 9.1.1 of Quality Control Inspection Procedure No.'300 dated April 1, ISS;, requires that the area inspector (1) inspect, (2) stamp and.date the Production Routing Sheet (PRS) in the space provided, and (3) stamp an,d date and enter quantity accepted in the final acceptance block of the PRS. Contrary to the above, regarding EDC jacket water pump parts that were manuf actured during the time period when defective jacket water pumps were being modified: i
- 1. Stamp and da'te had not been entered at Operation No. 90 and final
- accept block of PRS No. 03-426-08-AE Water Pump Shaft which was i processed in October 1982. Further', the quantity accepted had not I been entered in the quantity accepted block.
- 2. Stamp had not been entered in 'the final accept block of PRS '
Ho. 101969 Seal Retainer which was processed in Septeeter 1982. i G. Stone and Wetster Engineering Corporation $recification Ne. SH!-!9 catec June 24, 1951, provices the bidder witn the estion of testing or cynamic i
,ar.alysis of mechanical,eculpcent for seismic qualification, i
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Taragra:h 15.3.1 and its subparag ash 5 of E P 1 catec Acril 20,193*., sta.e that tne engine driven Jacket water pump will be shake testet. The
". Qualification Statement for 03-425-04 Jacket Water Cooling Pump Revision" dated October 18, 1982, states, in part, "We submit that tnese *
{ changes do not have any negative effect on the seismic qualification of l the subject pump . . . ." ! Contrary to the above, dynamic analysis' or testing had not bee'n. conducted. on the recesigned EDG jacket water pumps to assure that the seismic qualification had not been compromised. , H. Paragraph A.1 of E0P 7 dated April 20, 1981,, states, in part, "This procedure outlines those steps taken in accc plishing release er revision o' . . . purchase specifications." Purchase specifications cc..tain a space for approval. Contrary to the above, Purchased Material Specification No. RL 019000 dated October 6,1982, had not been approved as evidenced by the lack of a signature in the approval block.
- I. TDI's 10 CFR Part 21 report letter dated June 23,1953, concerning a potential problem with the isoprene flexible elements of drive couplings, states,,,in part, "a copy of this letter will be sent to each of the cognizant parties as listed in paragraph 2, no later than July 15, 1982." -
- Contrary to the above, the TOL notification letters to 10 af fected custe er cognizant parties were dated August 18, 1982.
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*- C F.",t:.it ? ATI C:i: TR A!ISAMIR!CA DELAVAL , INCORPORATE-5..-...-- - . . , -. --.--.e.,
EN'aINE AND CCMPRE55;R 0 V15:0N t.-..~. - . . - . . - -. .u-...... CAKLAND. CALIFORNIA f * ' ~ ~ "[ ',,G ; ^ ; , [ U g j g i., R PORT INSPECTION S Z : . .'.. ., , ,*r; a d u No.: 9?900334/E3-01 DATE(5) 7/11-15/83 Dea-SITE CURi: El CCRRE5p;;; GEN:! AGGRESS: Transamerica Dela ral, Incorporated , Engine and Compressor Divisien ATTH: Mr. C. Mathews, General Manager 550 25th Avenue Cakland, California 94251 ORGANIZATIONAL CONTACT: Mr. R. E. Soyer, Manager, Quality Assurance rgtt=vC':i NUMBEn- (a151 577-7a?? FRINC 7AL PRODUCT: Emergency diesel generators.
!;UCLEAR IN*,USTRY ACTIVITY: Transamerica Delaval, Incorporated (TOI) has no c :erent ec.. tracts fer domestic nuclear emergency diesel generators (EDGs).
A5 SIGNED. INSPECTOR: .t4 ' ' d.26 /h ? JOW. Sutton, Reactive and Co.ponent Program Otte / Y,ection (R& CPS) , OTHER INSPECTOR (5): W. E. Foster, R& CPS R. E. Oller, R& CPS . APPROVE 0 SY: . bem *
'I h-7 h3 I. Barnes, Catef, R& CPS Date INSPECTICN EASES AND SCOPE:
i A. SAsis: 10 CFR Part 50, Appendix 8 and 10 CFR Part 21.
- 8. SCOPE: This inspection was made as a result of the issuance of several 10 CFR Part 21 and 50.55(e) reports. The reports pertained to:
(1) incorrectly identified bolt material, (2) failure of high pressure fuel oil injection lines, (3) failure of Jacket water pump shafts. (4) failure of a crankcase cover molt, (5) unqualified isoprene ..aterial, sed (6) deficient pisten skirts. These cenditions i.ere observed singly or in :c..tination at one or more nuclear generating stations. t ' C,i !**! A: PLICAE!LITY: l . 1 N orre:.1y icentified bolt material: 50 :00. Failure of high pressure fuel oil. injection lines: 30 322, 50-206, 50-361, 50 362, 50 416, anc 50 417. (cent. en next page) g e e o .e . e
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CAf;LAno, :ALIFOR$'Ik~r ~~... e, ir.. v.uiu.liviT :'CA iv urn g p g_ " ION - . ~ " - U" 99900334/E3 PAGE 2 cf .. 1 i PLAriT SIT APPLICASILITY: (cont.) .
. ailure of jacket water pump shafts: 50-322. Failure of a crankcase cover
- o.t: 50-416. Unqualified isoprene material: 50-415, 50-417, 50-400, 50-413,
. 50-414, 50-424, and 50-425. Deficient piston skirt: 50-413, 50-414, 50-518, 50-515, 50-553~, 50-554, 50-400, 50-401.
l l A. VIOLATIONS: .- ! entrary to Section 21.21(b)(1) of 10 CFR Part 21 dated Decen:er 30, 1912, a cirector, responsible officer, or designated person had not notified
..a Co=-ission in regard to: '
- 1. Jacket water pump shaft failures on EDGs that had been furnished to the Shoreham Nuclear Power Station. .
~
- 2. A poteatial defect in the fuel injection line tubing that was used on EDGs furnished to Grand Gulf and San Onofre.
This is a Severity Level IV violation (Supplement VII).
- s. nonCONFORMARCES:
\ -
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, paragraph 4.6.2 of Section 4 of the Quality Assurance Manual (QAM) and paragraph 4.1.1 of Qual.ity Control Procedure I.P.200, the receiving inspector accepted material on Purchase Order (PO) 45333.,
for which required mill test reports had not been received, without issuing a nonconformance form P-249.
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part SQ and the ce=mitment date of July 15, 1952, in TDI's 10 CFR Part 21 report dated June 23, 1932, concerning unqualif'ied material in flexible drive couplings of EDGs, the notification letters were not sent until August 18, 1982.
i
- 3. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and subparagraphs II. A and II.B dated January 29, IS76, and November 10, 1969, respectively, of the Drafting Room Practice, the fell'osing layout drawings for the late 1982 redesign of the.EDG jacket water pues had not been (1) drawn'on tracing paper and.
l (2) signed and dated: (a) 101973, (b) 03-425-08-AA, and ! (c) 03-425-10-AE (lined thrc;;h). Contrary to Criterien V 'of Ap:endix 5 to 20 CFR Part 50, paragraphs 2.2 and 2.3 of Engineering Caerating Procecure (EOP) 4 ested April 19, 1979,.and paragrapn II.A.6 cated January 29, 1976, of the i
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REPORT IriSPECT10ti , ,.L' tio. : 95500334/E3-01 RESULTS: y'E ' h'*[ *,, Ton _ l_ PAGE 3 of 14 l l ' Drafting Room Practice, regarding calculations for the redesign of
' defective EDG jacket water pumps located at Shoreham Nuclear Power Station:
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- a. Calculations for the first occurrence (1979), which are written in the proper notebook, had not been signed and dated in the spaces provided. .
~
b. Calculations for the .second occurrence (1982) had not been
. (a) signed, and (b) written in the proper notebook.
- 5. Contrary to Criterion V of Appendix B to 10 CFR Part '50 and paragraphs 6.1.1, 6.2.1, and 6.3.1 of Section 6 dated February C7, 1981, of the QAM, "D Sheets" which pertain to quality of the product are issued by the Enginee' ring Department; hcwever, they are not reviewed by the manager as evidenced by the lack of provisions to identify the date, preparer, reviewer, approver, or revision.
l Examples are D-4986 and D-4956 which are entitled, " Assembly l l Instructions," and pertain to the EDG jacket water pump. It was noted that the latter document reflected the release date, four revision levels, and dates in the lower margin of the affected sheets.
- 6. Contrary to Criterion V of Appendix 8 to 10 CFR Part 50 and paragraphs 5.3.2, 5.3.3, and 16.2.1 of Sections 5 and 16, respectively, dated February 27, 1951, of the QAM, route sheets for the assembly of the EDG jacke't water pump reflected on Drawing No. 101973, Revision C, had not been retained by Quality Control as objective evidence of inspection acceptance.
~
- 7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and
' paragraphs 2.4.1 and 9.1.1 of Quality Control Inspection Procedure No. 300 dated April 1,1931, regarding EDG jacket water pump parts that were manufactured during the time period when defective jacket water pumps were being modified:
- a. Stamp and'date had not.been entered at Operation No. 90 and
! final a'ccept block of PRS No. 03-426-OS-AE water pump shaft i which was processed in October 1982. Further, the cuantity accepted had not been entered in the quantity accepted block.
- b. Stan: had not been entered in the final accept bicck cf PRS No. 101969 seal retainer which was prc:essed in Se:tember 1982.
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CROAN;:' AT:0N: - 1"- TR ANSAMERICA. DELAVAL, INCORPORATE'"7~ ~ ' ~ ' - " --* ' .$., ~ ~ ' '
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REPORT INSPECTION e-- i ., a-a.. NO.: 99900334/53-01
- RESULTS: G--*.-"'"-- - pAgg 4 ef 14
- 8. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Stone and ,
Webster Engineering Corporation Specification No. SHI-89 dated June 24, 1981, paragraph 15.3.1 and its subparagraph 5 of ECP 1-dated April 20, 1981, and the " Qualification Statement,for 03-425-04 j Jacket Water Cooling Pump Revision" dated Octooer 18, 1982, dynamic l analysis or testing had not been conducted on the redesigned EDG jacket water. pumps to assure that the seismic qualification had not been compromised.
- 9. Contrary to Criterion V of Appendix B to 10 CFR Pa 't 50, and papagraph A.1 of EOP 7 dated April 20, 1931, Purchased Material Specification No. RL 019000 dated October 6, 1982, had not been approved as evidenced by the lack of a signature in the approval block.
C. UNRESOLVED ITEMS: ;.
. None D. STATUS OF PREVIOUS INSPECTION FINDINGS: -
- 1. ~(Closed) Nonconformance A (Report No. S2-02):. The Quality Assurance / Quality Control organizational chart had not been updated to reflect changes in the QA/QC organization since January 1, 1982. -
The NRC inspector revie'wed the current QA/QC organizational chart which was revised on January 15, 1933, showing that the Hondestructive Examination (NDE) Level. III examiner is no longer the Manager of Qual.ity Engineering.
- 2. (Closed) Ncnconformance B (Report No. 82-02): Kobe Steel Ltd. had not been surveyed at a minimum of once every three years as required by paragraph 4.4.3 of Section 4 of the QAM.
The NRC inspector reviewed a revision to the QAM, subparagraph 4.4.5, issued April 22, 1983, which indicates tha venoors who hold current ASME certificates of authorization or Quality Systems Certificates need not be surveyed or audited. Chemical a alysis of sucject j- crankshaf t materials were performed and' the materials found to, be ac:ep acle. The NRC inspector was inf or. ed :y TOI that they intend to perform a physicil inspection at Kobe Steel Ltd. within tne next three months. 4 g , e em
ORG AC' At!CN: TRANSAMERICA DELAVAL, IN~ORPORATEi, ow w . w ....i.: . . . . . . . .
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ENGINE AND COMPRESSOR D: VISION ."----- " OAKLAND, CALIFORNIA ', ' I.' ,' ". '. ',T'_#,'.~.'j."''"'/2
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INSPECTION M '" *' * "'*
- 5
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NO.: 99500324/E3-01 RESULTS: PAGE 5 of 14
- 3. (Closed) Nonconformance C (Report No. 82-02): (a) Component drawings '
released by engineering did not constitute the final instructions to asse=bly for definition of acceptance criteria for the governor lube oil cooler, and (b) instru-tions for assembly of the governor lube oil coelcr had not been provided in writing from manufacturing
. engineering to assembly.
1 The NRC inspector reviewed the lube oil governor assembly drawing and verified 'that the 4ccation of the cooler was not identified. In addition, the parts list for this drawing was reviewed for content. The route sheet now indicates the a's-sembly drawing. TDI's corr'ective action commitments contained in the January 5, 1953, letter to the NRC have been co= plied with. E. OTHER FINDINGS AND COMMENTS: ( 1. Carolina Power and Light Company's (CPL) 10 CFR Part 50.55(e) notification report, dated January 18, 1983, identified that bolting material for the CPL Shearon Harris, Unit 1, EDG was not properly identified in accordance with design requirements. , The NRC inspector reviewed docu=ents and. correspondence between TDI, j Ebasco, and CPL pertaining to this subject. It appeared' to the NRC j inspector that a misunderstanding existed as to whether the bolts and ( nuts were requested to be fabricated to AISI 4140 or ASTM l specifications. The nuts and bolts were bought to the AISI 4140 specification which conforms to ASTM A193 Grade 87 chemical and mechanical property requirements. Specification CAR-SH-E-11, Revision 6, did not require ASTM materials to be purchased. TDI's - letter of June 22, 1983, to Ebasco outlines this finding. This is not considered a generic problem. -
- 2. Tennessee Valley Authority (TVA) 10 CFR Part 50.55(e) report to the NRC dated February 10, 1982, addressed the failure of TDI to take corrective action on TVA audit findings described. in TVA audit -
81V'-47, conducted December 1-3, 1981. Documentation and
- correspondence between TVA and TDI to date was reviewed. Reaudits have been performed by TVA to determine compliance to their findings.
TDI had taken action to make sure that preposed corrective actions were implemented before signing off on the corrective action . form. Documentation for compliance to this recuirement was reviewed. All o~utstanding items were elesec out by TVA during a TVA reaudit. TVA's letter to TDI dated August 24, 19S2, indicated no findings.
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g PORT "~~. -s -- J s' INSPECTION ~ No.: 9390c334/S3 RESULTS: PAGE 6 cf la
- 3. Long Island Lighting Company (LILCO) filed a 10 CFR Part 50.55(e) ,
' report on April 20, 1983, with the NRC, Region I. The report stated that failures had occurred in fuel oil injection lines to the EDGs that had been furnished to Shoreham Buclear Power Stat' ion, Unit 1. As a result of the documentation review by the NRC inspector, the following conditions were found to exist:
l
- a. Three diesel generators were supplied to the Shoreham Nuclear Station for emergency power.
b.. A failure occurred to the high pressure fuel oil injector line during routine testing of Generator No.102 on March 3,1982. The tubing was replaced and on March 5, 19E3, a fuel injection line failed on Generator No.103.
- c. Both lines were sent to an independent laboratory for failure analysis.
l I I -
- d. A failure analysis issued by TDI dated June 24, 1983, concluded that the failure was at'tributable to the presence of a discontinuity on the -inside diamete,r (I.D,),of the i.-jection tube.
This discontinuity acted as a stress riser and combined with the (. line operating pressures resulted in the fatigue endurance limit
- of the material being exceeded. The report indicated that the i discontinuity was a draw seam that had been created during manufacture of the tubing.
,e . TDI conducted a 10 CFR Part 21 meeting on June 27, 1983, as required by the Division 10 CFR Policy Procedure, to evaluate the findings and to determine reportability to the NRC. The committee determined that this problem was an isolated case and was not reportable. On July 5, 1983, another meeting was held which still determined the condition to be nonreportable due to the fact that many engines had been and are running with the same type of tubing that had.been installed at Shoreham.
- f. The NRC inspector requested a search be made as to when the
- tubing used in the Shoreham Units was purchased and if other nuclear sites could have injection lines installed that had been manufactured from the same lot of tubing. '
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ENGINE AND COMFREiS3R DIvlS10N -- OAKLAND, CALIFCRNIA j.M* U '[I'.'[ " " w8f. REPORT , INSPECTION hC.: 95500334/23-01 RESULTS: pA3g 7 cf 3a
- g. TDI searched their records and found that the tubing was r purchased in 1976. Purchase lots are made in 2000.ft.
increments with approximately 200 ft. being used per diesel unit. The reccid checks indicated that besides the Shoreham t nuclear site, EDGs had been furnished to Grand Gulf and San Onofre nuclear sites which had utilized tubing from the same purchase lot. ,
- h. TDI Design Specification D-265 dated October 2,1972, and Revisions A anc S dated August 18, 1972,.and August 15, 1920,*
contain the ap;1ica31e recuirements required to be followed in regard to tubin; manufacturing operations. The supplier was recuired to furnish material certificates of conformance and test reports with each order. Purchase documentation for this ' period of time (1975) was not retained by TDI in that the QA program only requires retention for 5 years. The NRC
. inspector revia ed a recent PO for tubing, No. 45333 dated October 1,1981, for conformance to purchase requirements.
The PO required that mill test reports be furni'shed. A nonconformance.was identified as a r,esult of the acceptance of the material by the receiving inspector, although mill test
. reports had not been received (see paragraph B.1).
- i. The action to preclude recurrence was contained in the failure analysis report, June 24, 1933, and indicated "more rigid QA procedures were called for. Sections from each length of tubing should be cut off, sawed lengthwise at 90? intervals, l and it,4pected to ensure there are no draw marks on the tubing l ID. 'Since draw seams would run the entire length of the tuning, this inspletion measur,e will ensure that no draw seams are present in any line manufactured from that length of tubing l (200 ft.). Such a QA requirement should De called for on any high pressure fuel injection line destined for use on a nuclear stand-by emergsney diesel generator."
- j. As a result of the NRC inspector's review of documentation,
. consistency of drawings, procedures, PCs, letters, in-house memos, and repcets, it was conc 1'uoed that this failure may not i be an isolated occurrence ano that a potential existed.for draw seams to be present in fuel injection lines of dies'El generators se;;1iec to Grand Gulf and San Onofre. In addition, revie. of 10 CFR Part 21 evaluation activities
.concerning tr.e fuel oil line f ailure consisted of sice nctes on letters and recceds, etc., produced by TDi personnel during l
Delivered Prod ct Trouble (DPT) meetings. These were censidered I l i ?
9 GRGA !II ATION: TRANS A.MERICA, DELAVAL, INCORPORfrTf.y a m n .-. .- ..------o
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GINE AND OAKLAND, COMPRESSOR [OIVI CALIFORNIA SI0tr
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REPORT I NS P E CT I O ,N. ,{", "',"" ,' ' ,' "', ' ' "" ',# ,
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NO.: 99900334/E3-01
- RESULTS: w..... c e sw ,- PAGE 8 of 14 L
as ' inadequate by the NRC inspector to establish the reason for , classifying this occurrence as one of a kind. The violation. , detailed in paragraph A was identified as a result of this review.
- k. Subsequent to the inspection, TDI filed a'10 CFR Part 21-report with NRC, Headquarters'. The report is dated July 20, 1983, and identifies the following nuclear generating stations with the potential defect: (1) Shoreham, (2) Grand Gulf, and (3) San Onofre.
- 4. LILCO filed a 10 CFR Part 50.55(e) report on October 15, 1982, with the NRC, Region I. The report stated that jacket water pump shafts had failed on EDGs that had been furnished to Shoreham Nuclear Power Station, Unit 1. ' Further, the report stated that the fa-ilures occurred on jacket water pumps that had been modified to preclude failures that had been experienced in similar units operating overseas.
The following conditions were observed during the course of the inspection:
- a. The Engine and Compress'or Division of TDI filed a 10 CFR Part 21' report on September 22, 1979, regarding "a potential failure of the drive shaft for the engine driven jacket water pump which
' would result in engine nonavailability." The report stated that jacket water pumps of the same design as those that failed had been installe'd on the three EDGs that had been furnished to Shoreham Nucicar Power Station. The NRC inspector was informed that the jacket water pumps had been modified.
- b. A TDI memo dated October 18, 1982, states, in part, "In the past five months, Lilco [Long Island Lighting Company] has experienced three jacket water pump failures." Inf o rmation presented as a record of evaluation was included in open areas of a form entitled, " Authorization For No Charge Billings" dated October 7,1982, and identified LILCO as the customer.
The following hand written / printed information was exhibited in the open areas: " Review 10 CFR 21 no-only site conditions at LILCO diff OK other plants not a 30 CFR 21 LILCO unjque only site with this preblem attencees (list of names date,c 10-11-82] LILCD is aware of problem TDI & LILCO will solve (signec, datec 11/11/32]." The infer .ation is not suf ficiently cetailed to enable an acequate evaluatien of the decision ~ regarding reportability. The failure of the jacket water pumps had not been reported to the Co.?.ission. As a result of i tte foregoing, the violation detailec in paragraph A was l identified.
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- RESULT 5; PA3E 3 of 24 i
- c. Layouts are created by redlining existing drawings rather than r by initiating new drawings. The redlined drawings (layouts) had not been subjected to the required signature /cate cycle.
Calculations had not been controlled in the manner specified. There was no indication that assembly instructions had been reviewed / approved. Route sheets for assembly of the jacket water pump had not been retained; also, some route sheets for manufacturing activity had not been completed as required. The foregoing, along with other observations, resulted in the nonconformances detailed in paragraph B.3 through B.9.
- d. A TDI maso dated July 16, 1979, which addresses jacket water pumps, identifies Gulf States along with LILCO and a foreign customer. Requested documents were not presented regarding Gulf States; as a result, this issue will remain open in order to determine whether or not Gulf States received suspect jacket water pumps.
- a. TOI identifies the cause as engineering and assemb.ly induced.
The NRC inspector concurs; however, in his judgement, the quality organization cannot be excluded. Based upon the observations of this area of the inspection, it is not i . apparent that adequate corrective actions and preventive measures have been taken. However, the NRC inspector was informed that the pumps.at Shoreham Nuclear Power Station have operated past the times of the previous failures.
- f. In an effort to assess the effectiveness of the corrective actions and preventive measures, the following areas were -
i evaluated: (a) change control, (b) manufacturing process cor. trol, and (c) records. This area of the inspection was accomplished by evaluating the following documents for recuirements and/or implementation,of requirements: 12 drawings, 3 specifications, 6 procedures, 3 sections of the QA Manual, 5 memoranda, 7 letters,'and 24 other documents , . identified as: analysis / calculations, packaging / shipping j . notifications, production routing sheets, qualification ( ' statement, material requisitions, autherization for no charge billing, failure analysis report, asse.-bly instructions, and requests for crafting room action. The findings are indi,cated at other locations of this report.
- g. subsequent to the inspection, TDI filec a 20 CFR Part 21 report dated July 20, 1953, with nRC, Heaoquarters.
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GRGANIZATION: TRANSAMERICA'DELAVAL, INCORPORATED p-o.. . - - - ~ " - - - - - t ENGINE AND COMPRESSOR DIVISION CAY. LAND, CALIFORNIA 3_',',,*,'.,.'.T.'.**.'_"*""
, . . , , . . i swi t rua AU Lin RE? ORT INSPECTION NO.: 99900224/23-01 ~ RESULTS: FAGE 10 of 14
, 5. Two 10 CFR Part 50.55(e) reports by Mississippi Power and Light r (MP&L) Company to the NRC were filed on March 22, 1982, and April 21, 1982. These reports cencerned the' shorting of the generator by a sheared crankcase capscrew head of a . Unit I, Division II, diesel generator furnished by TDI. This matter was reported in several interim reports by MP&L with the most recent one being Interim Report No. 6. .
- a. During a 24-hour perfor=ance test, the unit tripped on a
, " Generator Differential" which was accompanied by electri' cal arcing inside the generator. Later i.9spection verified that the stator insulation had been damaged and the head from a 5/3 x 11 threads x 1 3/4" long capscrew was embedded in the st. tor. It was determined that the capscrew head was from the diesel engine's rear crankcase cover. All of the capscrews were - i' replaced by the utility, and an analysis.of the failed canscrew indicated the head br'oke off due to low-stress fatigue cracking during service. This cracking appeared to- have been initiated
, by over or under torqueing of the capscrews. .
- b. Findines: Review of the problem with TDI's Grand Gulf site service personnel provided the following information: The source of the capscrew head found in the generator stator was from a top capscrew in the vertical crankcase cover. The screw shank was still in the cover hole. The screws are
,' classed as noncritical service and require torqueing of 60 fout pounds (Ft. Lb.). Since the metallurgical analysis indicated a fatigue failure mechanism, the cause appears to' have been over or undertorqueing coupled with operating stresses.
No information was available,te indicate when ghis incorrect torqueing may have occurred, TDI service personnel indicated that the site Bechtel craftsman would have had a minimum of two occasions when they would have removed and replaced the crankcase cover for bearing checks after the diesel generator was delivered to the site. In addition, they would have had a TDI instruction manual which showed the required torque value of 60 Ft. Lb. for i this size bolt while using a special lubricant. The TDI service personnel also indicated that this inciden; of a sheared screw head shorting the generator was a firs.t *.ime occurrence for the TDI diesel generators. The matter was discussed between.TCI ano M?&L personnel, but no meeting notes were made availacle to the NC.C ir.s;ector by TDI. l
.. . s' 4:GtNIItT:CN: TRANSA". ERICA DELAVAL, INCORPORATr.,. . vv u ... n.-,..--.............,._l'
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ENGINE AND COMPP.ISSOR DIVISION r-*"* -- -
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r.EPORT IN3PECTION ****'Ea NO.: 99930234/8.;-01
- RESULTS: ****"**
PACE 11 of 1 4 6. In 10 CFR Part 50.55(e) reports to the NRC by four electric utility ' companies, a misapplication of unqualified isoprene material in the flexible element of the couplings for dies.el generators suppided by TDI was identified. This material was not suitable for use in the high temperature oil atmosphere of the diesel generator and would. deteriorate rapidly in service. The couplings were manufactured by Koppers Company. The utilities reporting were: (1) MPLL for Grand Gulf Nuclear Station, Units 1 and 2; (2) C:&L for Shear:n Harris Nuclear Power Plant, Unit 1, (3) Duke Power for Catawba Nuclear Statien, Units 1 and 2, and (*) Georgia. Po-er for Vogtle Nuclear Plant, Units 1 and 2. This matter was also reported by TDI in 10 CFR Part 21 reports to the NRC on June 23 andsJuly 13, 1982.
- a. . The action necessary to, correct this deficiency was to change out the existing flexible element in the coupling with one made of neoprene which was suitable' material for service. TDI, in their report, identified 10 nuclear power plants which have affected diesel generators, and indicated these cognizant panties would be notified no later than July 15, 1982.
- s. Findines: The NRC inspector verified the following j information through observations, discussions, and review of l documents:
- l .
(1) The incident which prompted TDI to report on June 23, 1982, was a failure of a coupling flexible element made of isoprene in a nonnuclear diesel generator. The utilities reported subsequent to the above date. The suspect couplings were manufactured by Koppers Company starting in 1977 and purchased as stock items by TDI based on TOI's purchased material specification for
" Couplings-Elastomeric, Part No. AK-007-000," cated November 11, 1976. The original version of this specification did not specify the type material of the flexible element. After the above failure, TDI issued Revisions A, B, and C to the specification in ISS1, 1982, and 1983, respectively. Change A specified that the '
flexible element should be necprene which is a suitable materia 1. Change B specified service in a 175'F* oil i atmosphere, and Change C specified that the flexible ' element must have a 1/2 " wide red band on it to cistinguish it as necprene. ! . - _ , . . . _ _ _ . . _ . _ , . _ _ , _ . ~ , -
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- RESULTS: w_wiew '* ' U V PAGE 12 cf 14 t
(2) Re.iew of TDI notification letters verified that all e nuclear order customers with affected diesel generators , were notified of the deficiency. However, 10 of the TDI notification letters were dated August 18, 1982. This date was contrary to the TD1 commitment date of July 15, 1982, in their 10 CFR Part 21 report and resulted in the nonconformance identified in paragraph B.2. (3) 02servatien of a ecupling flexible element in the stores i capartment verified that it did not have a red band on it as required by Revision C of the purchase specificati ti. Hewever, this flexible element was identified only by part number and it could not be traced to specific , P0s placed with Koppers Company after April 25, 1983. , (4) Review of receiving inspection cards, " Vendor Inspection Report," for Koppers Company, indicated that the bases i . for receiving inspection of the couplings was Mil-Std 105 D.
* (5) Review of 10 CFR Part 21 evaluation records concerning the isoprene flexible element established that' records were inadequate to establish the cause of the misapplication and the basis for the determination that the item was
{ reportable under 10 CFR Part 21. The only records available were entries dated June 15 and June 22, 1952, in the DPT committee weekly log. The June 15, 1982, entry indicated ' Product Engineering was to co= pile a list of engines using Kopper's Elastemer GDV drive couplings, and the June 22, 1982, entry indicated that it was { determined that the Kopper's Elastomeric coupling was a l 10 CFR Part 21 reportable item and the responsible i individuals were to. issue the appropriate notification. l These DPT committee meeting notes did not provice . l ' sufficient information to show the bases for the evaluation (and do not appear to meet the requirements 10 CFR Part 21, paragraph 21.51(a) and (b)).
- 7. In five 10 CFR Part 50.55(e) reports to the NRC by three electric '
utility companies, a deficiency in the piston skirt er stings of i clesel generators was icentified. This matter concerned the - potential f ailure of the engine pist'en skirt castirgs of diese'l generators'su; plied by TDI. Such f ailures would result in the unavailability of the diesel ge.erators. The castings were , manufactured ey 701 between Dececter 1975 anc Octo er 19S1. l The utilities reporting were: (1) Duke Pu-er for the Cata-ca l Nuclear Station, Units 1 and 2; (2) TVA for Hartsville \ ' l i
sr. U.:E AT!a: TRANSAMERICA DELAVAL, INCORPORATED . '.' . 2 . 2 ., .~ . . ,' ,~, C ,' , . ] ,', ,~, { EN;;NE AND COM:RESSOR DIV1510N " * - - - - - - ---
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OAKLAND, CALIFOT.NIA
*****'.""7,'"_','_'""_.'"..-*'85 REPORT' ]NSPECTION NO.: 555; 134/13-01 RESULTS: PAGE 11 of 14 i
Nuclear Plant, Units 1 and 2, and Phipps Bend Nuclear Plant, Units 1 and 2; and (3) CP&L for the Shearon Harris Nuclear Power Plant, Units 1 and 2. This matter was also report'ed by TDI in a 10 C.:R Part 21 report to the NRC on October 28, 19S2. l The NRC inspector ascertai,ned the following information by l discussions and review of documents:
- a. _The incident which prompted TDI to recort was a failure of a type "-AN" piston skirt casting in early 1930. The utilit'es subsequently made their reports to NRC. Subsecuently, TDI produced a report entitled, " Failure Analysis No. 152, Piston
! Skirt, P/N 03-041-02-AN," cated June 20, 1923. This report i
included a description of events leading up to a change in foundry heat treating practice to include fan cooling of the castings. This cooling method was determined to have resulted in high residual stresses in the castings which, when combined with operating stresses, could result in failure of the [ . castings. The report also provided recommended corrective i measures including HDE, stress relieving at 1050*F, and i selective grinding of the affected castings.
- b. Review of six TDI notification letters verified that all l utility nuclear units with affected diesel generators were
. accounted for. The letters included a list of foundry shop order numbers and serial numbers of the affected castings to i
aid the utilities in identifying the suspect castings. The l 1etters also recommended that the castings be returned to TDI for NDE and, stress relieving if possible, or replacement with ! suitable castings, and return for reinsta11ation. As of this l inspection date, only Duke Power Company and Gulf States Utilities have returned skirt castings to TDI. I '
- c. Review of a current process routing for Job No. 69501 covering reprocessing of returned castings verified that corrective action was being performed under controlled conditions using
. process travelers, qualified personnel, and procedures. Other records reviewed for Job No. 69501 consisted of: (a) special i instruction specification No. 750R; (b) a certificate of compliance; (c) a packaging and shipping notification; (d) a r magnetic particle inspection report; (e) an NDE technician's l
cualification record; and (f) heat t eatment recores for
. Iron ASTM A-536, Grade 100/70/03 cas-ings. The review also
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REFCET . IliSPECTION v s G, . i u. e ;, y ' rid. : 99900334/E3-01
- RESULTS: PAGE 14 of 14
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included the original master engine book of records for ' diesel generator 5.N. 75018-2762. Within this area cf the , inspection, no nonconformances or unresolved items were j identified.
~
F. EXIT INTERVIEV: . Curing the exit interview, at which time the inspection findings were discussed, the NRC inspectors were informed by TOI's management that they ob1d take exception to all of the violations that had been icentified during the inspection. The 14RC inspector incicated that this e position would be identified in the inspection report. It. was determined by staff review subsequent to the inspection to defer issue of one violation which had been identified to TDI management until after performance of further inspectio'n. This violation subject pertained to inadequate evaluation records.
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y ATTACH!!ENT 8
. J
o Delaval Diesel Generator Ooeration Exoerience U. S. Nuclear Exoerience In 1974, the Long Island Lighting Company (LILCo) contracted with TOI.to purchase three emergency ciesel generators for the Shoreham Nuclear Power Station. This was the first order received by TDI to provide an EDG for a commercial nuclear power station. In the next seven years, engines for 14 other plants were ordered from TDI. San Onofre 1 Two TDI Diesel Engines Installed in 1976 - DSRV-20 Serial No. 75041/42, Rated at 6000KW (nominal) > 8800KW (peak) Engine Run Time to Date - 450 hours per engine The first plant to actually place a TDI engine into nuclear service was San ,
- Onofre Unit 1 (SONGS 1), which purchased two V-20 units to provide emergency power for its feed pumps, which also serve as Emergency Core Cooling System pumps. ,
The engines at SONGS I were installed in 1976, and declared operational in
- April 1977. Since then, SONGS has experienced some problems with the
, operation of the engine turbochargers, a lube oil pressure sensing line
, failure which resulted in a fire, and several other minor problems. Because '
- SONGS did not commit to meet the guidelines of Regulatory Guide 1.108, but rather Regulatory Guide 1.9, the program it used to test the engines before they were placed in service was more abbreviated than for a new plant. A detailed list of problems to date follows.
Date - Problem Cause/ Solution 12/80 Excessive Turbocharger No lube oil during stancby. thrust bearing wear. Lube oil system modified. 10 CFR Part 21 report issued ! because problem generic. 7/81 Lube oil leak and fire. Excessive vibration of a lube oil test line which had inadvertently been left installed by the licensee. Line removed. 12/81 Piston modification to Pistons reworked by TDI to i
, prevent crown separation. respond to Part 21 report.
Problem identified at Grand Gulf. . l 9/83 Unqualified instrument Replaced in accordance with , cable. Part 21 report, f 1 l P i '. -
l l
- 2.- ,
Grand Gulf , , _ . Two TDI engines installed - Model DSRV-16 i Serial No. 74033/34 Rated at 7000KW Operating Hours to Date - Division I = 1100 hours; Division II = 700 hours In 1981. Mississippi Power & Light (MP&L-) commenced pre-operational testing of two V-16 engines installed at Grand Gulf Unit 1. They represent the first V-16 units ordered from TDI, and in fact, one of the Grand Gulf engines was used to qualify the entire TDI Y-16 line of machines for nuclear applications. The Grand Gulf engines have experienced significant problems in completing the pre-operational test program, have had several major failures, including a fuel line break which caused a fire, and many minor failures. A detailed list 4 of problems at Grand Gulf follows. Date Problem Cause/ Solution 11/81 Piston crown separation during Holddown studs failed. operation. Pistons returned to TDI for rework. Generic l problem. 3/81 Excessive turbetharger t'hrust No lube oil during standby. - bearing wear.
~
Lube oil system modified. i l 6/11/82 Air starting valve capscrews Response to Part 21 report. replaced. Too long for holes. 8/23/82 Flexible drive coupling material Replaced with different
- incompatible with operating material.
environment. 8/82 Latching relay failed during Relay replaced. testing. l l 3/8/82 Air start sensing line not Sensing line relocated and seismically supported. properly supported. 1/29/82 Governor lube oil cooler Lube oil cooler relocated to located too high. Possibility lower elevation.
. of trapping air in system.
3/23/82 Engine pneumatic logic Pneumatic logic design improperly design. Could corrected. result in premature engine shutdown. l =
- 3-
' Date Problem Cause/ Solution 4/29/81 Non-Class IE motors supplied Motors replaced with Class 1E with EDG auxiliary system qualified motors.
-pumps.
- 3/15/82 Crankcase cover caps' crew Capscrews replaced with failed. Head lodged in higher strength screws.
generator and shorted it out. Lock tab washers installed. j Gen,erator screens installed. 8/2/83 High pressure fuel injection Manufacturing defect in line failed. tubing. Tubing replaced. 9/4/83 Fuel oil line failed. Caused ' High cycle fatigue of major fire. Swagelock fitting. Additional tubing supports to be installed. 8/11/83 tracks in connecting push All push rods replaced. rod welds. 1983 Turbocharger vibration. Turbocharger replaced. 1983 Cracked jacket water welds. Excessive turbocharger vibration. Cracks re-welded. 1983 Turbocharger mounting bolt Excessive turbocharger failures. vibration.- Bolts. replaced. 7/83 Air start valve failures. Cause unknown. System cleaned and several valves replaced. More frequent maintenance scheduled. 1D/28/83 Fuel oil leak. Tubing replaced. l Cra:ked push rod weld. Push rod replaced. L During EDG Cylinder head cracks. Head replaced. l , i Installation 12/83 Cy1inder head cracks. Two heads replaced. . 12/83 Cracks in piston skirts All Division II pistons on Division II EDG. replaced. Divis' ion I pistons to be inspected. 9/83 Unqualified instrument cable. Replaced in response to Part 21 report. (
-r--- . - . - - - - - , - - - ,--,,,--,n.--,-cr.--,r.-,e-- --,---.w,. ,-,wy,-wme,w--,-.-,,,,,-- . . . ,
t Shoreham , Three TDI Diesel Engines installed, Model DSR-48 Serial No. 74010-12, Rated at 3500KW. Operating hours at time of crankshaft failure (8/83)
#101 = 646 cracked: crankshaft)
#102'= 718 failed crankshaft) 4 -
#103 = 818 cracked crankshaft)
The engines at Shoreham are the first straight-8 units to be placed in nuclear service in the U. S. One of the Shoreham engines (#101) was used to qualify the straight-8 series (R48) diesel engine for nuclear service. Pre-operational testing of the engines at Shoreham started in late 1981 and
- continued until the major failure of the #102 crankshaft on August 12, 1983.
After the performance of extensive tests in late September and early October, which were observed by staff members from NRR and Region I, as well as an NRC consultant, LILCo presented the results of its crankshaft failure investigation in a meeting on November 3, 1983. It reported that the crankshaft had been improperly designed, and had failed because the loading function used in the original design. calculations was too small. LILCo also i reported that it was investigating four failed connecting rod bearings which
- .were discovered when the EDGs were disassembled. Their preliminary finding i
.was that the failures occurred because the bearing' material did not meet
. specifications, an'd the bearing loads had not been properly accounted for. '
A detailed list of the EDG problems at Shoreham follows. Date Problem Cause/ Solution l 3/81 Excessive turoocharger thrust No lube oil during, standby. j bearing wear. " Lube oil system modified. 12/81 Piston modifications ,to prevent Pistons reworked by TDI to crown separation. respond to Part 21 report. Problem identified at Grand Gulf. 9/82 Engine jacket water pump Water pumps reworked by TDI. > modifications.
~ '
6/82 Air starting valve capscrews Responso to Part 21 report. replaced. Too long for holes. 9/82 Engine jacket water pump shaft Pump s' hafts redesigned and failed by fatigue. replaced. , I Spring /1983 Cracks in engine cylinder heads. Fabrication flaws. All heads replaced. -
)
Date. Probl em ,. Cause/ Solution 3/83 Two fuel oil injection lines- Manufacturing defect in ruptured. tubing. Tubing replaced with shi.elded design. 3/83 Enginer'ocker arm shaft bolt High stress cycle fatigue. failure. Bolts replaced with new design. 8/12/83 Broken crankshaft. Cracks in Inadequate design. Replaced remaining crankshafts. with larger diameter crankshaf ts. 9/83 Cracked connecting rod bearings. Inadequate design and substandard material . Replaced with new design. 10/83 Cracked piston skirts. Replaced all piston skirts
- with new design. Generic probl em.
11/83 Broken cylinder head stud nuts. Replaced all head stud nuts.
~
9/83 Cracked bedplates in area of Cracks evaluated by LILCo and main journal bearings. determined to not be i significant. 9/83 Unqualified instrument cable. Replaced in response to Part 21 report. 4 i a e e 9
. p e
I
^
.. --- ._. s _ _ _ - - _. -,_.
- 6- ,
Ooerating Experience - Non-Nuclear ,, , 1 Marine Apolications ,_ .... Besides being used for stationary electric power generation, TDI diesel
, engines have been placed in service as propulsion units on comercial cargo . - vessels. As part of the Shoreham operating license hearing, an intervenor, Suffolk County, requested and was granted by the Licersing Board, subpoenas for the State of /.laska, U. S. Steel, and Titan Navigation, Inc. These three organizations operate vessels whi,ch use TDI V-16 diesel engines'which are very similar to most of the TDI units installed in nuclear power plants. The responses which were received.inoicate that the TDI engines in marine service for these organizations have experienced severe reliability problems. Most have related to faulty cylinder heads, but they have'also included problems with pistons, cylinder liners, turbochargers, cylinder blocks, connecting rods, connecting rod bearings, main journal bearings, and camshafts. A catailed experience list follows. The staff is reviewing this material to see how much of it is applicable to engines in nuclear service.
- 4 i.
e G P
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. m.._ y,,,,m,._.,__ , - ..
' ~ ~
7_ Marine Exoerience with TDI Diesel Generators 1 State of Alaska, M'. V. Columbia Vessel fitted' with two DMRV-16-4 Engines - Serial No. 72033/34 Rated at 9200 HP (6900 KW) at 450 RPM Vessel and engines placed in service in June ~1974 Each engine has approximately 30,000 hours of operating time to date. Document Date Problem DescriotiorI
.F 12/76 All cylinder liner seals replaced. All cylinder heads have been removed,.
reinstalled, or renewed at least three I times.
'. All pistons have been removed and
. reinstalled at least once.
, Turbochargers have been removed, repaired ! o and reinstalled, or renewed 16 times due to leaking oil seals, vibration, rotor damag*, or defective bearing sea'l housing. 3+ Exhaust manifolds have been removed and !..ii reinstalled because of frozen expansion
- l. t joints and resulting cylinder head flange l1 face damage.
Lube oil consumption'is excessive. g s,
.c 6/15/78 Rapid deteriorations of fire seal rings
.x . causing blowby across gasket surface of i ,
cylinder heads.- Very low lube oil filter life (40 hours).
~
g ' Caused by blowby of pistons and valve guides. Stainless steel exhaust bellows burn out rapidly. Installed backwards by TDI. 11/28/78- (Letter to Alaska from TDI). Recomends timing changes to improve t turbocharger perfomance. ,
+
l 31 e l
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- Document Date Problem Description .
1/31/79 Valve seats and valve guides not concentric. Results in bad valve contact. Defective piston rings shipped as
- replacement parts.
Reworked cylinder head received from TDI without all required modifications and , with damaged gasket face. Newly furnished cylinder liners received with incorrect surface finish (twice). Connecting rod bearings furnished as spare parts were wrong size - 13" vice 12". i Turbocharger exhaust flex section incorrectly furnished by TDI. ' 2/2/79 Chrome plating failure of piston rings. Caused heavy scoring of cylinder liner. Associated cylinder head four.d cracked. Seven cylinder heads replaced during 15 weeks of operation. Excessive lube oil filter change out rate. Due to piston blowby. Fuel injector spray tips changed at TDI - reconnendation to reduce carbon buildup
. and eliminate washing of liner wa,11s with fuel oil. ,
Three major overhauls of engines in 5 years of operation. Carbon accumulations in rocker box areas. Excessive oil vapor discharge from engine
. crankcases.
Heavy carbon deposits on valve springs. Suspect valve blowby. , When exhaust valve guides were modified by ' TDI, they did not follow the procedure outlined in their SIM (Service Information Memo). h 8
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Document Date Problem Descriotion Loose piston pin end caps. Incorrect piston crown to skirt bolt
,- torque.
Bad connecting rod bearings. Excessive wear, cracks. Damaged connecting rod bolts. Valve push rods cracked at weld of ball to pipe. QC problem. Crankshaft size changed after engines for
. ship installe.d. No notice to owners of reason for change.
Excessive main bearing wear. Camshaft lobe hard facing worn.
. TDI recommended the installation of a new .
flexible exhaust duct which was too short (new design). Installatic, attempted at insistence of TDI. Unit damaged by attempt and returned to TDI for repair. 3/19/79 QC or material problems with respect to non-concentricity /out-of-round valve seats, push rods, rod bolts, bearing shells, valve stem plating. 6/14/79 Thermal growth and cracking of exhaust manifold. 12/26/79 Failure of new connecting bearings.
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Cracks of 25% of connecting rods. e e e
Document Date Problem Descriction 1/16/8b Ten (10) new cylinder heads have cracks. This includes 8 that were previously repaired.
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Fifteen (15) valves are defective with chrome flaking off the valve stems. Valve. stems are being defomed. Five additional push rods have cracks. Turbocharger air cooler inlet housing is cracked for fourth time. Internal' bracing.in engine intercoolers is cracked. 2/5/80 Piston rings installed improperly because mistake by TDI in the drawing used by TDI shop. 2/29/80 Piston crown-to-skirt nut torque inconsistent among nuts on various pistons. Excessive link rod bushing bail wear caused by improperly relieved, drilled oil I passages on the matching link rod pins. 3/24/90 Abnomal carbon deposits and formations noted on pistons and cylinder head
. ' assemblies.
l Fretting of jaw areas of connecting rods. Insufficient turbo '(manifold) air except at near full speed operation. Cracked exhaust manifold end plates. l Cracking of connecting red boxes. ( . l Cracking of newly installed connecting rod bearing shells at 4500/ hours. 1 I
Document Date Problem Description,, Fretting of link rod and link rod pins at their attachment together. Fretting between link rod bushings and* link rod bushing bore. Galling of link rod bushings in way of l link rod pin outer drilled. oil passages. Improper wear / contact pattern on newly installed connecting rod bearings at 4500/ hours. Four-point loading. Insufficient connecting rod bearing
- wear / contact area to journal wherein it is less than 15% of the total bearing area.
Upsetting of stems in valve keeper area. Damage to number four piston ring and ring groove on all pistons modified during the 1978-79 engine teardown and rebuilt after 4500/ hours operation. Fretting between piston crown and skirts at 4500/ hours since piston modifications. Variations in piston bolt torque, beyond
- specified limits, at 4500/ hours since -
! piston modifications. i Damage to rod bolts, including cracking, l and damage to threads on both the bolt and l in the rod boxes. 7 4/18/80 Exhaust manifold conversion kits received i with cuts and grooves in finished * ! surface. Required rework by owner before installation. 5/12/80- rods received without New connecting required code (American Bureau of Shipping) i . approval. TDI did not have record of which
, rods were shipped with approval or without approva1.
Some new connecting rods shipped with - oversize bearings but no note to customer informing of difference. 6
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- 12 -
Document Date Problem Descriotion 5/14/80 Cylinder head returned to TDI has been lost by TDI. Cannot be located. 5/15/80 Customer received new connecting rod bolt in rusty condition with damaged threads. 5/27/80 Customer received reworked cylinder heads
. with lip left on exhaust seats which prevents valves from seating. -
Customer noted that it now was in 4 possession of two cylinder heads with the same serial number. Could not install lockwire in new connecting rod cap screw. Hole drilled partway through with drill broken off in center of hole. Also noted that edges of lockwire holes on other screws had not i been rounded to prevent damage to lockwire. , 5/29/80 Discovered leaks in newly installed
. exhaust manifold head plates.
9/4/80 (MeetingSummary) TDI says that all cylinder head problems should be corrected by new design. . 4 TDI reports that connecting rod bearing ~ cracks could have resulted from bad bearing alloy makeup by vendors. TDI looking at different bearing materials. TDI stated that they had erred on piston modifications. Effected others besides COLUMBIA. ! 9/30/80 Eleven remaining master connecting rods to be sent to TDI to have oversize bearings and other modifications installed. Ma'ny of the original cylinder heads that were returned to TDI for rework were exchanged for other used heads.' l .
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Document Date Problem Descriotion - 11/6/80 Cylinder head changed due to heavy 4 external water leakage. Severe smoke causing excessive lube oil - contamination and engine room atmosphere probl ems. Engine secured to prevent possible crankcase explosion. 12/10/80 All connecting rods removed. New rod cap screws and washers to be installed because l' . increased torque specified by TDI caused galling. New connecting rod bearing shell found cracked. Heavy wear noted on piston side thrust areas. Heavy hard carbon buildup noted in . area of canpression rings. Fourth ring
- groove area to be reworked by TDI due to design / machine error by TDI during previous modifications.
Nineteen (19) of 32 cylinder liners exc'eed , spec for out-of-round. TDI to modify limits to permit continued usage. Twenty-one (21) of 32 liners lost crush. " . New phenomena. Repairs require machining i
- of engine block.
Fuel injectors removed and to be changed from 140' spray pattern to 135' pattern. Original nozzles had 150' pattern. 1/16/81 Cylinder block bores found to be distorted. Four new engine camshafts installed. l i
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. Document Date Problem Descriotion 3/13/81 Reworked cylinder heads were returned to the customer without removing the grinding compound from the valves and valve seats.
Two reworked pistons returned to customer without roll pins, which lock the securing
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nuts in place. Cylinder liner delivered with wrong surface finish. . Cracks found in cylinder blocks. All replaced. Main engine blocks found to be cracked and wa rped. The main block-to-base through bolts appear to have been improperly torqued during initial assembly. One "new" camshaft found to be a rebuilt unit containing several damaged bearing journal areas. The threaded head stud holes in the new cylinder blocks were not counterbored deeper, as TDI had indicated they currently do. This was to eliminate cracking of the block near the stud holes. The customer re-machined each of the 256 head studs to accomplish the same intent. 4/9/81 Several reworked pistons were returned without groove pins. In response to a request for 20 11" capscrews and washers, TDI supplied 17/8" capscrews. , Drawings furnished by TDI for head stud modifications were not applicable to the studs in question. 50% of the fuel pump bases would n'ot fit onto the new cylinder blocks be'cause of ' slight changes in the design of the blocks. l . l - l _ _- -. ~ . . _ ___..._. _ . _ _ . . , _ . . _ _ . _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ __
f I l Document Date . Problem Descriotion Two new cylinder liners provided with incorrect surface finish. One new cylinder liner provided with flange thickness larger than
. manufacturer's maximum tolerance.
New connecting rod capscrews were found to be galled and unfit for use. . 4/29/81 Service manual showed incorrect installation of. engine camshafts. 2/3 of fuel cam tappet assemblies on one engine could not be installed on one engine because the new cylinder blocks had not been properly counterbored. Cylinder liner :ounterbore depths were off to such an extent that difficulty experienced in establishing proper liner crush. Weld spatter noted on many seating l surfaces. 3 Dirt, sand, and metal shewings found in passages and holes which should have been clean. Cylinder head water port outlet locations varied considerably, causing a water flow i restriction. Air start distributor not properly assembled at factory.
. 6/1/81 Exhaust manifold head plate developed a leak. Cracks found around 2 of 3 tie rods due to poor initial welding.
11/19/81 Defective valve springs found on.one
- engine.
7/29/82 Valve rotator failed. Cracks discovered in the intercooler. I
Document Date Problem Description 7/29/82 -
"In nine years of operation every basic l engine component has been modified or replaced with an improved item, at least once, with the exception of the crankshaft (which is obsolete and has not been used for years), the engine base, the fuel pumps and the governor. The last.two items are not manufactu ed by TDI."
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10/15/82 Turbocharger 1 replaced. '
. Exhaust valve lubricating system to be installed.
3/9/83 Cracks discovered in three cylinder heads. Reworked cylinder returned 'to customer with tap broken off in threaded hole. Others returned with internal cracks and damaged flange faces. l I l l l I
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l I* L .
' Titan Navigation, M. V. Pride of Texas ,
Vessel fitted with two DMRV-12-4 engines, Serial No. unknown Rated at 7800 HP at 450 RPM Engines installed 1981 - no information on total engine hours to date. Document Date Problem Descrfotion 7/16/82 Catastrophic piston failure. Due to crack in piston skirt. Engine had 5791 hours of operation. 4/1/82 Cylinder block broken and cracked. Cylinder head cracked. Cylinder liner cracked. Piston skirt fractured. . Suspect that all of above problems caused by water leaking into cylinder from air intake manifold. Leaking tubes found in air intercooler. 8/19h82 Cracks discovered in six piston skirts. 7/22/32 Cracked exhaust valve seats in cylinder heads. Engine had 3000 hours service. Camshaft lobe desigr$ appears to be deficient. Causes excess'ive stress on fuel cam lobe and roller. J Tappet. assembly rollers severely galled. Believed to be due to camshaft and lobe placement and inadequate heat treatment. , ! Fuel cam lobes have failed twice due to
- improper heat treatment.
Chrome plating lost from one piston wrist pin. All four intercoolers have failed because of erosion due to high fluid ve,locity. , l Air start valves have suddenly ceased to i function, for no apparent reason. i (
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Document Date . Rroblem Descriotion Plugs in crankshaft oil ways may be - cracking because improper material used. Under investigation. Fuel oil return lines have failed. To be replaced with heavi.er wall tubing. 4/1/83 Exhaust valves fail after about 2000 hours of use. Serious problems with cylinder head cracks. Turbochargers experiencing difficulty supplying sufficient air.
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U. S. Steel, MY E. H. Gott - Vessel fitted with two DMRV engines (model unknown) Engine Serial No. 75039-40 No information on engine hours to date. Document Date Problem Descriotion 11/13/80 Cracked cylinder head. Replaced. 11/1/79 Cracked cylinder head. Replaced. 6/1/80
- Cracked cylinder head. Replaced.
10/8/81 Cr'acked cylinder head. Replaced. Note: This information was summarized from documents provided by U. S. Steel in response to a subpoena which asked specifically for information about cyliner head failures. Many other portions of the documents were deleted by U. S. Steel, ind it appears that the deleted portions referred to probless with other engine, parts. O E o e 6 e
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Other Aop11 cations The staff understands that other TDI engines are in service as stationary electric power generators. The operating history of these engines will be taken into consideration during the staff assessment of TDI engines. e O 9 e 4 e 6 e e
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Reference List Shorham ,, .. [ Letter dated 1/6/84 from 8. McCaffrey (LILCo) to H. Denton (NRC) Board Notification 83-160 dated 10/21/83 Board Notification 83-160 dated 11/17/83 Letter dated 12/9/83 from J. Smith (LILCo) to T. Muley (NRC) Letter dated 12/9/83 from A. Schwencer (NRC) to M. Pollock (LILCo) Letter dated 12/29/83 from A. Schewncer (NRC) to M. Pollock (LILCo) Letter dated 12/16/83 from C. Matthews (TDI) to T. Novak (NRC), Letter dated 12/16/83 from J. Smith (LILCo) to T. Murley (NRC) l Letter dated 12/16/83 from A. Dynner (Suffolk County) to A. Earley (LILCo) I. Letter dated 10/20/83 from A. Earley (LILCo) to L. Brenner (NRC) i Letter dated 10/16/83 from R. Boyer (TDI) to NRC Letter dated 11/17/83 from A. Earley (LILCo) to L. Brenner (NRC)
- IE Infomation Notice 83-51, dated 8/5/83
!! Inspection Report 99900334/33-01, dated 10/3/83 IE Information Notice 83-58, dated 8/30/83
- Grand Gulf - - .
. Letter dated 11/15/83 from L. Dale (MP&L) to H. Denton (NRC)
Letter dated 10/19/83 fromL. Dale (MP&L)toH.Denton(NRC) , LER'50-416/83-171/03L-0 dated 11/28/83 Letter dated 10/26/83 fromL. Dale (MP&L)toH.Denton(NRC) LER 50-416/83-082/01T-0 LER 50-416/83-126/01T-0 I e e
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o. San Onofre Unit 1 LER 50-206/81-017 dated 8/12/81 Letter dated 9/15/81 from.H. Ray (SCE) to R. Engelken (NRC) LER 50-206/80-039 dated.12/23/80 Letter dated 6/8/81 from J. Haynes (SCE) to R. Engelken (NRC) Marine Applications Letter dated 12/21/83 from A. Dynner (Suffolk County) to A. Earley (LILCo) Includes many.other individual documents. e b ,
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4 e 4 4 l 1 e 0 e t 4 L
Ge LP-34 ATTACHMENT 9
\
. Vendor Insoection History l
.. e I
To date, the Region IV Vendor Inspection program has inspected the TOI
- l facility in Oakland.. California, nine times. The following inspection reports '
- have been published in the POR regarding these inspections:
- 1. Docket No. 99900334/79-1, dated 3/20/79 ,
- 2. Docket No. 99900334/80-01, dated 1/22/81
- 3. Docket No. 99900334/81-01, dated 5/27/81 4 Docket No. 99900334/81-02, dated 9/18/81 e e
- 5. Docket No. 99900334/82-01, dated 4/15/82
- 6. Docket No. 99900334/82-02, dated 12/8/82
- 7. -Docket No. 99900334/83-01, dated 10/3/83 Attached is a summary by the Vendor Inspection Branch of the T0! inspection hi sto ry. The history includes some results from the last two inspections, which are being reviewed for proprietary information, and which will be published when that review is complete.
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I 1 ATTACHttENT l TRANSAMERICA DELAVAL INSDECTION HISTORY r VENDOR PROGRAM BRANCH FINDINGS 1979-1983 MANUFACTURING PROCESS CONTROL: 1.- Performance of required inspections for completed operations on Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment could not ce verified, in that neither inspection acceptance stamps were present on the route sheets 'for the completed operations nor were inspection reports available to indicate rejoctable conditions had been found upon inspection. .
. 2. Route sheets were not available to confirm required inspection acceptance of assembly operations for the emergency diesel generator (EDG) Jacr.et water pump reflected on Drawing No. 101973, Revision C. .
. 3. Absence of evidence of inspection acceptance for co'mponents manufa tured during jacket water pump modifications performed in September anc October 1982.
- 4. a. Acceptance signoff by QC inspectors was made on route sheets in-regard'to installation o'f rocker arm hold down bolts. These bolts were subsequently found to be missing on inspection at the Shoreham Nuclear Power Station (SNPS).
- b. ShipmentofreworkedpistonstoSandnofre, Unit 1,priortodates
- indicated on route sheets by QC inspectors that various manufacturing operations were accepted. ,
- 5. a. Route sheets not issued for rework of 92 pistons from $NPS and Grand Gulf EDGs and there is, thus, no evidence of inspection acceptance of the various manufacturing operations,
- b. No records of quality activities for rework activities on Grand Gulf EDG pistons which was a specific requirement of the procurement specification.
- 6. Absence of required NDE reports for SNPS replacement cylinder head castings.
- 7. Apparent use of unqualified personnel for performance of NOE operations on SNPS replacement cylinder head assemblies.
- 8. Improper signoffs and dates for acceptance of SNPS replacement cylinder heads with respect to personnel identity and use of a surrendered inspection stamp prior to expiration of the minimum 6-month pitriod.
9,
- Use of a different hard facing welding procedure specification to that specified on the route sheets for valve seats in SNpS replacement cylincer head assemblies.
- 10. Requirements not provided for welding of and acceptance of Snearon Harris EDG fuel oil line clamps.
a
. 11. Prior to October 1981, manufacture of piston skirt castings did not comply with engineering component drawing instructions with respect to performance of specified stress relief heat treatment.
- 12. Route shee s for Job No. 02933 did not provide instructions in regard to swaging operations performed on crankshaft oil plugs.
- 13. No assembly route sheets available for SNPS replacement cylinder head assemblies.
. CONTROL OF SpECIAL PROCESSES:
- 1. Absence of procedures for examination of Level III NDE personnel and failure to qualify personnel performing visual examinations in accordance.
with ASME Code requirements.
- 5. a ~. Performance of vertical up position welding on ASME Section III piping (Shop Engine Ao. 2931, Shop Order No. 94302) by welder qualified only for flat position weldin' g.
- b. Welding of a 2'-inch ASME Section III piping assembly by unoualified welder. -
- 3. Observations during three different inspections of failure to return unused welding electrodes in required 4-hour issuance period.
- 4. Identif tcation of welders used for certain operations on Shop Engine Nos. 2931 and 2959 could not be verified.
- 5. Unacceptable fillet weld size in Shop Engine No. 2931 Tank Lube 011 Sump Inlet Compartment due to bad fitup of tank roof and sidewall resulting in ,
almost flush condition. .
- 6. Use of welding electrode sizes that were not permitted by applicable welding procedure specifications on Job Nos. 94922 and 96632.
- 7. Use of Job No. 95395 of welding amperage and voltage in excess of welcing procedure specification requirements.
- 8. Performance of welding on Job Order No. 97-485-3085 without specified revision of welding procedure specification being in welder's possession.
- 9. Certification records for nondestructive er. amination persence1 die not indicate the use of ten checkpoints by the examiner during tne practical examination as required by SNT-TC-1A and internal procacures.
PROCUREMENT CONTROL:
- 1. Failure of Quality Engineering to both update Qualified Supo11ers List every 3 months anc to provide a monthly summary of vendor quality ratings to QC and Purchasing.
A
1 j l l , . 2. Evidence not available to assure that the seller of auxiliary tube oil ane jacket water pump motors complied with the requirements of the purchase order.
- 3. Betts Spring Company, a supplier of critical valve springs, had not been
, surveyed every 3 years. The,available evidence showed it was approximately 5 years since a survey had been made.
4 Associated Spring Company (Barnes Group) was placed on the Approvec Suppliers List and used for procurement without completion of a survey or audit.
- 5. Kobe Steel Ltd., a supplier of. crankshaft was not surveyed every 3 years as required by the quality assurance program. .The only available record was a self* evaluation survey. form completec by Kobe Steel's American representative. .
- 6. Fuel oil tubing for Purchase Order No. 45333 was accepted *by receiving inspection without issue of a nonconformance report, although regi. tired mill test reports had not been received.
- 7. Purchased Material Specification No. RL 019000 dated October 6, 1982, was not approved as. required by Engineering Operating Procedure 7.
- 8. . A QA program was not imposed on the manufacturer of exhaust silencers for EDGs furnished to Perry, Units 1 and 2, as required by Perry Specification Nos. SP-750-4549-00 and SP-706-4549-00. '
- 9. Purchased material specifications for engine mounted electrical control cables required only commercial grades of cable and did not invoke applicable customer specification requirements. . '
- 10. a. No available evidence to indicate that materials which were used to fabricate EDG ASME Section III Code Class 3 component supports (Midland),and fuel oil systems (Midland and Grand Gulf) were procurec -
from vendors who were either identified on the Approved Suppliers List or had been subject to audits,
- b. Prior to 1982. ASME Section III Code fasteners were procurec from vendors who had neither been au'ditec nor were identified on the Approved Suppliers List as being approved for supply of tnts product.
- 11. Acceptance by receiving inspection of ASME Section III Ccde faster.or certifications which did not comply with purchase order requirements with respect to: (a) conformance of chemical compositten to material specification requirements, (b) completeness of mechanical test data and (c) compliance with ASME Section III Code reovirements for reporting of material heat treatment.
,o .
- 12. Failure to comply with testing requirements of paragraph NCA-3867.4(e) in the ASME Section III Code wher. purchas1ng stock materials from unsurveyee vendors.
i MATERIAL 10 ENTITY AND CONTROL: . Eleven discrepanc'ies in material identity observed in a sample of 45 between the identity of material issued and that recorded as being used for Midland EDG S/N 77002 piping system component supports. DESIGN AND DOCUMENT CONTROL: ,
- 1. Failure to comply with Division Standard Practice Nos. 4.101 and 4.201 requirements with respect to:
- a. Relaase of a drawing revision to the shop without receiving approval of the applicable Engineering Change Notice from Industrial .
Engineering. .
- b. Maintenance of the Engineering Change Log, classification of enanges as major or minor, and initiation of required forms.
- 2. Parts Itst and component drawings released by Engineering did not define acceptance criteria for installation of crankshaft oil plugs. -
'; 3. Absence of any . instructions' in* regard to instaliation location of governoi
, lube oil cooler to engine. * ,
4 Failure to comply with Orafting Room Practice dufing 1932 redesign of the EDG Jacket water pump in regard to certain layout drawings no's being either drawn on tracing paper or signed and dated. ,
. 5. Dynamic analysis or testing not performed in accordance with Stone & -
Weester Specification No. SHI-89,after redesign of'the SNPS EDG jacket
- water pumps.
2
- 6. Failure to comply with Engineering oc ating procedure 4 and Orafting Room Practice requirements with respect to signing and dating of calculations by the designer for the SNPS jacket water pump redesign.
- 7. No evidence of required approval of "O Sheets" by the applicable Engineering manager. Examples noted were 0-4986 and 0-4956 wnten were entitled, "Assemoly Instrugttens," anc pertainec te the EDG ja:1.at water j pump. .
. 8. Jacket water pump analyses dated Septercer 24 and Octoeer 4, 19S2, and July 15, 1963, for SNPS nad not received requirec certifica:1on from the staff Registered Professional Engineer. I s
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r NONCONFORMANCES AND CORRECTIVE ACTION:
- 1. No evidence to indicate that required quarterly submittal of completed
, corrective action activity to the Division General Manager had ever been accomplished. *
- 2. Failure of Quality Engineering to process a required Corrective Action Request Form after customer identification of TOI failure to meet wele
' quality requirements in ASME Section III Code Class 3 ciesel generator piping. *
- 3. a. Removal and replacement of a defective weld in Shop Enginer No. 2931,
- Part No. 07-717-02YR, without required rejection and documentation on an Inspection Report. ,
- b. Ot sposition of a dimensional nonconformance on Shop Engine No. 2931 Part No. 02-540-07-87, made by QC supervision without required submission of the Inspection Report to the Material Review Board for review.
. 4. Failure to comply with ASME QA Manual requirements with respect to immediate identification of nonconforming items, on Inspection Reports and
. segregation of the items. *
- 5. Weld shop audit not performed in the fall oY 1981'in accordance with
, corrective action commitments made to t eh NRC. . ,
EQUIPMENT CALIBRATIO'N: >. 1. Actual calibration measurements for micrometers and a pressure gage were not recorded as requiped by Quality Control Procedure No. IP-100.
- 2. Gage used to measure, accept / reject the diameter and depth of the link rod dowel counterbore had not been identified in accordance with OA program requirements for calibration equipment.
- 3. Measures were not established to assure that tools usec in crankshaft oil plug installation were properly contro11ec and adjusted at specified
, periods to maintain accuracy within necessary limits.
^
4 a. A welding machine in Wald Area No. 3 (Foundry) was observed in September 1983 to hav'e calibration stickers showing a calibration due case of August 30, 1980. The OA program :stibrati:n freouse:y requirement for this equipment is 12 months. .
- b. A heat treat furnace was observed in September 1983 to have calibration stickers on the meters and temperature recorder snowing a calibration due date of March 13, 1983.
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. INTERNAL AUDITS:
' Failure to perform required semiannual audits of the Foundry, Manufacturing and support activities.
10 CFR pART 21 PRACTICES: . {
- 1. Records were not ava.ilable with respect to fractured thermostatic control valves in Grand Gulf, Unit 1, EDGs to indicate either tnat an evaluation had been conducted in accordance with 10 CFR Part 21 reautrements or that actions had been taken to determin,e whether the product deviation contributing to the valve fractures (i.e., improper use of raised face flanges in connecting piping) was 'present in eauipment suppliec to other customers. .
- 2. Notification to affected parties in regard to.a potential problem with isoprene flexible elements of drive couplings was made after the committed date_in the 10 CFR Part 21 report.
j 3. Failure to notify the NRC in regard to:
- a. Jacket water pump shaft failures at $NPS. .
- b. Potential' defect in' fuel injection line tubing that was used on'EDGs furnished to Grand Guld and San Onofre, Unit 1. -
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. 0A RECORDS: -
( 1. Records not available to demonstrate environstntal qualification of auxiliary lube oil and jacket water pump motors with respect to Bechtel Specification Nos. 9645-M-018.0 and 9645-G-QA-1.
- 2. Failure to prote'et records against fire in accordance with QA Manual requirements noted during two separate inspections.
MISCELLANE0US: Failure to have Certificate of Compliance for $NpS replacement cylinder head
- . assemplies notarized in accordance with customer , specification recuirements.
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TRANSAMERICA DELAVAL, INCORPORATED VENDOR PROGRAM'5RANCK.IN5DECTION H!5 TORY
SUMMARY
0F NINE IN5PECTIONS DURING 1979-1983 ,
, Number of Subject Nonconformances/ Violations Manufacturing Proce'ss Control 13 Control of Special Processes 11 -
Procurement Control 12
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Material Identity and Control 1 Design and Document Control 8 Nonconformances and Corrective Action . $ Equipment Calibration ,
. 4 ,
Internal Audits -
. 1 10 CFR Part 21 Practices 3 (Violations)
QA Records '3 Miscellaneous . 1 . O O O 0
1 sc $35 ATTACHMENT 10
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! . UNITED STATES OF AMERICA - 1 NUCLEAR REGULATORY COMMISSION 2 --
3 4 l 1 s j
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7 8 8 A Meeting on TDI DIESEL GENERATORS 10 l 11 12 l 13 14 Phillips Building Bethesda, Maryland is - Thursday, January 26, 1984 16 17 ; I L 18 l l 19 ; A meeting on TDI Diesel Generaters cen'.ened 20 at 3:04 p..:. , Harold Denton presided. i 21 22 - 23 1 24 28 i B e
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- ( Attendance List will.-be - Generated. )
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- 1. i MR. DENTON: Good' afternoon. My name is l
2' Harold Denton. What we are going to discuss today is l 3 the results of the staff review of the reliability of f 4-the Delaval diesel. :
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-3 I i
We started looking. intensively in this area : 6 when problems began to develop at San Onofre, Grand Gulf, 7 and at Shoreham. Since that time, our review has er.-
, a panded. l
.s. '
We are prepared today to discuss with you in i
-t to . detail the results of all the information that has come 11 to our attention regarding the operating performance of 12 ~these diesels. -
I 13 , We also have with us today the Regional Ad-
.3 14 ministrator from Region IV, John Collins, who conducts
*' I 15 cur v'endor inspection program. He will describe the Is results of his vender inspections at the factory of 17 -
Delaval Diesels. 18 l I understand that the Owner's Group has is been informed of the utilities who own these diesels, 20 and they are represented today by Jim McGaughy, who is 21 , the Chairman of the Owner's Group. I understand that 22 the Chief Executive of Delaval Diesel Corporation is 23 also present, and that his representatives will be 24 making a presentation. 25 Let me discuss a few ground rules to begin 4
I 4 l 1, with, to make the meeting go smoother. We ara taking a j t-2 transcript of this meeting. The issue is in contention, 3
.am you know, at several proceedings. And this makes it l 4
easier for us to provide the Hearing Boards a complete i p i 8 and accurate record of what information is made available f - l e today. . ! Because of this transcript, it's very i=portant - l 7 that anyone who has questions or comments be sure to
- 8 identify themselves for ,the record when they ask questions. ' ,
t 9 Tne way I would like to walk through this cro- '
. 10 i cess is to have the staff first describe in some de- !
i 11 tail the information that has become available in the 12 last few months on the performance of these diesels in , 13 the field. This is mainly at nuclear power plants, but 14 I we also collected data from some non-nuclear sources. 2 ! yhen, we will cover the vender inspection, as l 18 I mentioned. . Then, we turn the =eeting over to the 17 utility Owner's Group, aho I understand is prepared to 18 , describe their remadial program to try to establish the 19 ~ reliability of these diesels. 20 I understand, Jim, that you may have an Open-21 ing -- openi.ng' remarks to say before we begin. Nhy don't Z! , you do that now?
- ZI 1R. McGAUGHY: Good a'fternoon. My name is 24 Jim McGaughy. I am Vice-President of Mississippi Pcwer.
25
.and Light Company., I am speaking to you today as Chairman l
S
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1 of the Delaval Diesel Owner's Group. i I 2 i The issues that will be presented here, we i f 3 I feel' the problems that have been found in our pre-operation i 4 testing program and our subsequent research and reported I 5 - to the NRC, as they've been found, 'using the proper pre- t 1 a ! scribed methods. For some time, all the owner's of these i 7 engines have bound together putting the best minds avail-8 :
- able in the world on these issues in the one effort to j
'9 study and correct these issues. i
~
.10 Cur goals and the goals of the NRC are the 11 same.
We are committed to provide our plant to reliable i 12 emergency backup power supplies. We feel this comprehen-13 . 1 sive program we.have in place, in place now, working now, . t 14 l will do just that. a' l . We are here today to tell you about what it 16 is that- we I have been doing. The elements of our program 17 j are four.
- The first element is resolve the known problems,.
18 } l both generic problems and proble=s in the specific engines 18
; themselves , to design and find fixes to these problems.
2 i i i In addition, we will take -- and are in the 21 l process of taking each engine from the ground up, review-H .- ing its design, its construction, its procurement and 2 doing a quality revalidation on each and every engine. 24 From the results of the quality revalidation, then we 3 l go into testing, and the testing involves non-destrurtive
.I
4 .. -- --- i 6 i . , I i 1 I testing, destructive testing, operational testing of { 2
.. components, operational testing of the engines.
This 3 work is in progress now. 4 And also then we will, through this group, 5 respond to the questions, of course, that the NRC will a put to us. The participants ' in our program are as : - 7 follows. We have the eleven owners, and I will have a ' s list of those for you later. Eleven utilities. FaAA i 9 !. Associates, who are renown h doing failure analysis work. , 10 We have the wholehearted support of Delaval in this ! 11 effort, ? both in gathering of indormation and gathering P n of design data, and in review of this data. Stone and
- 13 ..
1 Webster, Engineering is supporting this effort. And also 14 l several diesel generator consultants from around the I 15 l world. Is , I The organization the Owner's Group has set ue ' l 17 . has me as Chairman, I-Ir. Joe George of Texas Utilities as 13 f Vice-Chairman. Executive Committee made up of the eleven i 19 - utilities. I f The Technical Director of the program is Mr. 20 l Bill Museler of *ILCO. We have taken ene program tha: l 21 l LILCO has started on their site , adding to it. The work 22 is being done, at the LILCO site. n l As you see, in resolving the known failures and 24 : determining solutions to those proclems , FaAA is takin: p 2 the lead; ena: is their speciality. In terms of desbgn
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7 i 1 review and quality revalidation, we have FaAA,' Stone and i 2 Webster, our various consultations, and we have engineers 3 from each utility working in this effort. The testing i i 4 i program definition - and carrying out the testing program , 5 will be donc, of course, by the utilities who own the i e engines and operate them, and by raAA who' will assist us 7 in that e f fort. a 73 aive you an idea of the extent of this pro-9 i gram,.I would like to put this chart up. This is the i 10 organization enat is in place. We have over a hundred and ; 11 twensf peepic full-time working en this effort, working on u this effort now. This is in progress. We are confident 13 that when we complete this program, that we.will have 14 reliable enoines to provide backup power supplies for these u l pl ants . 16 Thank you. . 17 MR. DENTON: As those of you know, who own la these diesels, this is a very i=portant safety issue for I 19 the "RC. Tac re are about fifty-seven engines made by a Transamer es Delaval that are in this, owned by the six-21 teen utilt:Lcs that are on our list. None of the Celaval
, i 22 j diesels are it operating plants, which means it's net an 2 imminent sifa:- : -problem today, but certainly it has [r -
24 ; found inni .:stiens for schedules for some of the util ties 25 , if the proclom is not adequately addressed. r I i I S
. _ ,- - + - - , w w =ww--e--=-p- w
8 i I i 1
'I did want to mention my perspective on the
'2 safety side to be sure it's well understood. ,
The only i ' 3 plants that are operating that have Delaval diesels are ! 4 San' Onofre Unit 1. That plan,t is shut down for a seismic l l
-i 5
modification. Grand Gulf, which is limited to a five ; s percent power license and is presently shut down. .And, , 7 Rancho Seco, which is usine other diesels, but I under-8 stand has ordered, or has in place, several Delaval . diesels; g which they have intended to install. ! l to We view' this as a verv serious problem for the [ l 11 industry. It is unique to have a problem in what I will ' call a convention component of American technology. 12 You 13 wouldn' t think that diesel generators would get on the 14 critical path of the nuclear power reactors, but that's 15 I very likely wnat has happened. - 16 And just so there is no doubt about where the 1; n staff stands on this issue, we are not prepared to go 13 forth and recommend the issuance of new licenses on any 1 t 19 plant that has Delaval diesels until the issues that are l l 2 I raised here today are adequately addressed. It sounds l-21 like we have a very ambitious program. What I want to de 22 , is make sure you have all the information we have. 23 l And if we come to an understanding about the 24 : factual basis that we are working with, so we can move 2 l ' i to a discussion of the information we have been able to e i E i e
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9 I t-I 1 i gather, and if everycne would hold their questions to the l 2 ' l extent they can, we can get through the presentations ! a faster. ! 4 We will provide ample opportunity for discus-5 sion after we have gotten the factual basis. on the table. 8 , Then, we will turn to a detailed presentation of your j 7 program. And I plan to provide a break somewhere in the*
- 8 meeting.
But we will probably go until about six o' clock. !
- 9. ,
The first presentation will be made by Frank 10 Miraglia and assisted by Carl Berlinger. Carl Berlinger 11 is a Senior Manager on the NRC staff. We designated him ' i 12 as the person respo'nsible for ultimately reviewing your ' 13
. program and making sure that it is an acceptab'le, adequate ,'
14 prograni. . 15 l So, Frank, why don't I turn over to you to !- 16 cover what we know about the operating experience. 17- MR. MIRAGLIA: My name is Frank Miraglia. I 18 l am the Assistant Director of the Safety Assessment Divisic:J l 1e i of Licensing. t 20 he first view graph is a list -- the firs t 21 view graph indicates the fif ty-seven Delaval diesels that l 22 have been procured for use at sixteen different nuclear 23 power plant sites. t May I have the second view graph? 24 f We are going to discuss the U.S. experience 25 ! with these diesels in the operating stations to f ate. i I
' - ~ -
)
10 ! i t The next slide is a brief summary of the operat ! 2 ing experience with San Onofra 1 station. The informa-3 tion on this view-graph is in a very summarized f ashion. 4 I
~We have a more detailed handout that will be available '
, 5 at the end of the meeting that has additional details i e I about the operating experience and chronology with some t 7 of these machines at the various nuclear power stations, a , There are two Delaval diesels at San ono fre 1. , s They were installed in 1976. They are Delaval V-20 10 engines. They were declared operational in 1977. The ' t 11 e operating time on each engine at San onofre is approximate-
- u ly 450 hours.
These are actually the first Delaval diesels: i
'u to enter nuclear service. -
14 Problems to date are indicated on the slide. u They've had turbocharger thrust bearing problems. This I is event resulted in a Part 21 report, was issued and pro-blem was considered to be of a generic nature. 17 L I L 18 i They've had a lube oil lee.k and fire, which I is was a result of a fuel line failure, test line off a labe 20 oil line which failed because of vibration. And it was a 21 small fire. i ! 22 ! The pistons have been modified at San Onofre 1 i _ t 23 : to correct a problem that is noted at Grand Gulf and 1 i i 24 l 6 resulted in a part 21 notification there, to prevent er wn i 25 ., separation. l i I. i
.,,,,,%. ec-+-*
11 : 1 They've had an unqualified instrument cable, 2 ' which also was replaced in conformance with reported j s 3 Part 21 occurrence. And just recently in another Part 21 4 report, there fis potentially defective coupling material. s That Part 21 report,was filed earlier this month. . ; i
. i l l e
The next slide is a summary of the experience ' l 7 l ,on the -- of the Grand Gulf diesels. They have Delaval 8 diesels. They are the V-16. The operational hours on l 9 the diesels are 1100 hours on the Division I diesels, . j 10 and seven hundred hours on the Division II diesels. 11 These are the first V-16 Delaval diesels to a enter. nuclear service. The problems to date are the -- 13 Number one is the pistol crown separation. That was a ' 14 generic problem and identified this particular problem f 15 ' as a Part 21 for the Delaval diesels. la They have experienced piston skirt cracks, 17 ; and piston skirts have been replaced on the Division :: l 18 ; diesels.
- 1 13 They've had a fuel line failure, which resulted I
20 in a fire. And the fuel line failure was due to fatique. l [ 21 They have experienced cylinder head cracking on these n . diesels. The heads have been replaced. m In addition to those, they've had the turbe-24 . charger problems. I believe three dif feren instances Of I 25 turbocharger problems. And, again, you can see commOnali '.'
12 i
. i I
between this experience 'and he San Onofre experience. 2 They have experienced push red cracking pro-3 blems. In addition, they've had the generator short due ! 4 to an engine fastener. This was a crankcase capscrew 5 failed and had Lodged in the generator and shorted the ' 8 l generator out. . 7 In addition, Grand Gulf has also experienced . a problems w;:n their air starting valves which has resulted ! i 9 in failure of the generators to start. l : to This summarizes the experience with the San l 11 On,ofre and the Grand Gulf units. I would like to have u Ralph Caruso summarizg for you the experience to date 13 . on the shorenam machines and also to present a brie'f 14 summary of the information that we have been abic to
!15 gather from non-nuclear marine experience,with similar 16 type diescis. ,
17 Ralph Caruso. 18 '!R. CARUSO: The engines installed at Shoreha I tg ! are :*odel CE R-4 8, straight-8 engines. They are rated at bek ~ 20 3500 kilewa :s and meew approximately 700 hours roughly 21 on each ena;nc at the time o f' a major f ailur'e o f crsnk-Zt shaft in Aa=ust of 1983 . zi These engines were the first straight-3 engines i 24 i to be ins: Tiled in the United States in service. Shereham 25 has had a nameer of minor eroblems and one major probier. l 4 .
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I 13 1-To date, they've had problems with jacket water 2 pump propellers. This problem occurred twice.
., Two fuel f, 3
~ oil lines ' have ruptured due to manufacturing defects. !
t 4 I Those two ruptures resulted in Part 21 reports being is- l sued for San Onofre and Grand Gulf. i i e In August they had the failure of the crank-7 shaft in the Number 102 diesel generator. Subsequent ' e inspections of Number 101 and 103 engines revealed cracks ; g in the crankshafts of those engines, and in approximately , to the same location as the failure of the 102 engine. i 11 . Upon disassembly of the engine to repair the ~ k b ear,*e 12 crankshaft problems, connecting rod faikures were dis t3 covered, not' just on the engine with the failed crank-14 shaft but also on another engine. Subsequent inspection i 15 l revealed problems with piston skirts, with cracks in the 16 piston skirts'. Those piston skirts have been. replaced at i 17 I Shoreham. i ; Is ! And, in audition, over the life of the plant i 19 i they have experienced several problems with different 20 l ; types of fasteners used to attach critical components :o-l 21 l
, gather in the engine.
22 i The staff has received a considerable a=ount 23 of information regarding marine experience from three 24 .different operators o f =arine eng:.nes.7kMarine 4 t
. eng:nes ceh 25 W e. 1 l
' are talking about, +e the V-16 and V-12 engines . They areOf I
l -
o 14 i 1 very similar, if not identical, to engines that are being !' 2 installed in nuclear power plants in the United States. i j 3 ! The operating experience for these engines is i 4 varied at this time, with engine operating hours varying 5 from 3000 to 30,000 hours. To date, all three operators a have reported cylinder head cracking to varicus different 7 extents. ' i e Two operators have reported piston cracking. l t + One operator reported the complete failure of two pistons. l lo Problems have also been noted with excessive l-l 11 bearing wear, turbocharger instability, and turbocharger [ 12 vibration. Cracks have been noted in push rodyyaames. k: # 2 Cracks have been noted *in connecting ' rods. 14 a In addition, cylinder blocks have been replaced M by one of the operators. 16 This is a summary of the marine experience to L 17 date. 13 MR. DENTON: We have given you a very quick l i is , summary, but there is extensive information available in 20 what we will hand out later in the presentation. 21 . And just because we have gone throuch it quickl*;, 22 ! I don't want you to think that this is all there is. There . l n , is really quite a bit of poor operating history with this i ! 24 piece of equipment in the time that we have been able :o l 25 assemble it. i l 1 t i l i ! I l I L- --
.._-_.__,_,,__u-.,-_._..____ _ - - - - , . _ _
15 j l l i 1 1 I think some of the reasons for this poor l I 2 performance- will be obvious when you hear from our next I, 3 speaker, John Collins, who I mentioned heads up the f 1 4 vendor inspection program. John. I, 5 MR. COLLINS : Thank you, Harold. Now, we are - e passing out the view-graphs which cover a summazy of the 7 major findings that we've had of the inspection. 4 Since 1979, we have made nine inspections of l 9 Delaval. Seven of those inspection reports are identified to in handout material. They are available in the PDR. If n 11 you would like copies and you cannot get copies, contact u myself in Arlington or Ian Barnes of our Vender Br'anch, i u we will be very happy to see that copies of these reports 14 . are sent to you. . 6 3l The remaining two reports have been forwarded gg to the Company for proprietary review. That review , 1 g- period should be up tomorrow. If there are not any pro-14 l prietary problens, they will be placed in the POR and they will be available, too. So, if you want to contac e, to a my number in Arlington is Area Code 817-860-82 5. Or, 21 Mr. Barnes, same area code, 860-8176. i 22 We have -- as I hope everybody has the slifes 23 now, our finding of deficiencies covered ;us about e'r e r* * ! 24 subject. They included areas on anufacturing process
- nt :1, l 2 control, control of special processes, precurenent, i
1 t I
.. - - - _~ - -- .. - . - - .
l . 16 ., I 1 - material identity and control, design and document control,' 1 2 equipment calibration, lack if. internal audits or improper j i 3 or not. sufficient disposition of audit findings, and then i 4 deficiencies in QA records. . 8 At this time, I am going to ask Ian Barnes, l 8 who is the Chief of the Reactor Section for the Vendor ! l
- 7 Program to go through some of the highlights of the l 8 inspection findings with you. We are not going to read ,
l 8 them to you. You have them, but I think it's important 10 we at least identify some of them. l 11 The other handout material has a more complete 12 summary of all of the findings that were made or documented ni in the nine reports. So, Ian, why don't you walk us 14 through some of the significant findings'? ! 15 MR. BARNES: Good af ternoon. The first slide , to that is on now shows a categorization of the vendor i 17 program branch inspection findings by subject area. It I I is ! represents a total of sixty-two non-confor=ances and I 19 violations that were issued as a result of the nine in-l 20 spections. 21 As John has just indicated, a description of i Et l all of the findings in that particular slide are in-23 . cluded in a handout that is being passed around. rom i i ! this inspection history summary, we have extracted 24 zi examples o f inspection findings that raise concerns ctn . 6 i l , t n
17 1 1 regard to - the adequacy of implementation and the effective-.' t t 2 ness of the Transamerica Delaval program. ' l 3 The next slide, please. The first subject ! l 4 cm going to address is manufacturing process control. t 5 We have put apccific examples of inspection findings in ' i e a subject area, o'ut bringing the question.of 'implementa-7 tion ef fectreeness, manufacturing process controls, and a the perfor ance of quality function of Transamerica , 9 Delaval. ' to ?ss fou will note from this slide, instances 11 were noted saere route sheets were not available to 12 the vendor F ranen review. For example, the first item on i 13 the slide, Jacket water pump. Reworked operations for 14 l ntnety-two pistons that were supplied to Shoreham and Grand 13 Gulf, that's the fif th item. Replacements of cylinder I is head assemblies for Shoreham, th&t's the final item on
' 17 ; the slide.
- la I .Reute sheets from Transamerica Delaval erovide I
19 l the primary basis for verifying that the inspecticn Opera-1 2D ! tions haen . ecn performed. The absense of those route 21 l sheets di. not allow us to verify that required inspections 22 j of manufse ur.ng operations had, in fact, been accomplished. n , .;xam=les of findings which address the per-24 for=ance >i :nc :uality control function is shown in :hd 1 25 second, :n rd and fourth items, i.e. there was no e'/ dence
. - ---- --- ~
13 i i I 1 of acceptance of certain operations on components for 2 jacket water pumps pertaining to modification efforts. I 3 As Ralph indicated earlier, there had been 4 two successive problems involving jacket water pump pro-s bloms at Shoreham. And, so evid.ence of sign-off to , e installation of rocker arm hold down bolts were found 7 subsequent at Shoreham, were found subsequent to be mis-a sing. 3 In regard to San Onofre, piston reworked, wi th to the date of sign-off for manufacturer operations occurring i 11 actually two to three weeks after the pistons had been ut returned to San Onofre. 1 13 If you look, in regard to the seventh item on . 14 this list, is the apparent use as indicated by the route I 15 t sheets of unqualified personnel performing non-descriptive Is e::aminations on SNPs replacement ylinder head. I < 17 i The eighth item, which is an absence of any i la documented provisions for control of installation of Is i duel oil line clamps in regard to Shearon Harris. We
- 20 ,f believe that's generic to all of the encines, in that one 21 of the fuel oil line failures at Grand Gulf has been i
Et ! attributed in part to the absence of required line clamp. El We believe this finding is quite sienificant. 24 It has been r.entioned earlier about cracki..: 25 problems in piston skirts. Review of engineerine fra'nnes I e
.,_,_,__.-,---wm---~ - - < - - = *=-
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19 1 for the various designs of piston skirts show, in fact, 2 daat there was an engineering requirement to perform l 3 stress relief heat treatment after normalizing of the cas tings .
~
4 The corrective action that', in part, is being 5 carried out for piston skirts is to perform stress relief. l s There was an initial requirement a3 ways in effect to do 7 that very thing. 8 The next slide. This s_ide shows a few ; examples of inspection findings in regard to procurement { to document control deficiencies, use of vendors, the materials 11 that without performing any service or audits of those i 12 . vendors to establish adequacy of their own programs , and [ t 13 inadequate receiving inspection.- ' 14 In the more comprehensive handout that is beine - 15 distributed, you will find additional examples of inade-ts quate receiving inspection and using other vendors withou i 17 performing required service or audits. i u ! :: ext slide. In the area of material identity I to l and control, an inspection of this subject showed eleven 20 disc repancies were observed in a smaple of forty-five, 21 , I believe, in material identity between that recorded at 22 the time of the misuse of the material' to a given cb and 23 ; the identity of the material that was recorded on the i 24 : finished engine. 25 l :: ext slide. We have included the next Slide l l I
20 ; i 1 to show examples of the failure of the quality issuance t l I 2 function to comply with both QA program requirements for j 3 corrective action and non-conformance conditions to be i 4 identified and the specific instance of failure to comply t s with corrective action commitments made to the NRC in l s regard to the performance of their ASME weld shoe. .. 7 In the same context, their ASME weld shop, recurring ex-8 amples were noted during successive inspections for e f ailure to enforce program ' commitments with respect to l 10 control of welding electrodes in regard to that console , 11 moisture. u Next slide. The next slide is an additional I 13 example of the failure of the QA function to comply with 14 program requirements for audits of their manufacturing i I 15 activities. l' ts ! The final slide, John. l t We have included this L 1 17 l to illustrate that we have certain concerns in recard to* 18 f the adequacy of the Delaval evaluation and reporting i 19 practices in regard to 10 CFR Part 21. l I
- 20 24R. COLLINS
- As we indicated at the 'ecinning, I
- . 21 we have, summarized in these slides the findings. Su
- ,
22 as I also. indicated, I think there is a lot mo're that's 2 of interest.' If you carefully review the findings ths: 24 I were handed to you that were documented in the handeut t: i n ; . you, one thing it says to me, in my opinion, is tha: 1 I L__
21 1 not only has there been problems at the manufacturing 2 shop but also, in my opinion, calls into question the 3 adequacy of the vendor programs or surveillance proghams 4 that are being conducted by the utilities. Had some of 5 these been identified up front by utilities on-site e inspection programs, or receiving inspection programs, or - i 7 procurement programs, I think they could have been identi- ' s' fled even sooner than now. i j So, it really calls into question your own I i io programs. Darrell. l l gg MR. EISENHUT: Well,let'ssee,wewentthrough! 02 the two aspects in such a short.snmmary fashion, the t u operating experience and the 1nspection findings, that one f ,
-14 might draw connections that they infer, or might leave it 2 to the operating experience, these were meant to be short 16 summaries. We certainly are going to be, on the staff, 17 undertaking a more detailed look at all these aspects,
, 18 l in both the experience, the inspection results. 19 j As mentioned earlier, Carl Berlinger is heading ! 2D ! a major review effort. But I guess you have :o si: eack , 21 and say: Where does this leave us right now? L , n ; And right now, our preliminary conclusion -- ' l i
. 23 . and that conclusion is based on these limited icoks -- is l 24 that certainly our level of confidence in the overall y reliability of TDI diesels in general is significan:1f 5
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t i 1 reduced. We've got to say that from the front end. l i 2 And, secondly, as Harold Denton mentioned in j 3 the beginning, is that before we undertake the licensing I 4 of any plants with TDI diesels at this time, these issues 5 clearly are :otng to have to be addressed. These issues f 6 are clearly *.he quality' aspect from both the design, the
. 7 construction, the operating.experienes is going to have ,
a to be f acecred in, and the overall ability of these dieselsi I 9 to reliabl, perform their function is going to have to 10 be demonstrated. i gi ,That's basically where we are today. As we , 12 said early, tnd Jim McGaughy pointed out, there is a f 13 major indus'try undertaking, a major program has been laid : 14 cut, that we hope is going to address all of these issues. , is i And, obvious 1,y they are going to have to address them to 16 the staff's satisfaction. l 17 With that as a short su= mary, I guess I would is like to open it up to the staff presentation for any 19 questions be fore we go to the second part this af terncen 20 on either tece, the operating experience piece, or en 21 , the ins)ce:Lon esults found today. Any questiens?
' ~
22 (*hs reply. i -an't get off that easy. i
~
23 . .;w i l , if there are no questions, why don't i 24 ! I suggest .: ould probably be easier, Ji=, on ; cur 5 ; presents: on af we took a short break now rather than 1
- j I
l
[
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107 ,; 1 CERTIFICATE OF PROCEEDING I i 2 This is to certify that the attached proceeding before 3 the NRC Staff ; l 4 .In the matter of: Meeting on TDI Diesel Generators ; 5 < Date of Proceeding: January 26, 1984 ' 6 ' Place of Proceeding: Phillips Building, . Bethesda , Maryland
, was held as herein appears, and that this is the original l
4
, transcript for the file of the Commission.
~ 10 i
^
11 , 12 MYRTLE H. TRAYLOR Of ficial Reporter - Typed 13 14 15 Official Reporter - 32.gnad 16 - 17 18 I I 19
- 2o ;
l i 21 l 22 i - 1 I . 3 . 24 4
F ~ i l ATTACHMENT 4 m -
r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
~
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
Shoreham Nuclear Power Station, ) Unit 1) )
)
)
TESTIMONY OF ROBERT WEATHERWAX, MOUA"00 CL CACCEIP AND GREGORY MIMOR ON BERALF OF SUFFOLK COUNTY Q. Please state your names and professional affiliations. My name is Robert K. Weatherwax, Jr. I am the president A. of Sierra Energy and Risk Assessment, Inc. , of Sacramento, California. I have had 15 years experience in matters relating to nuclear ' safety analysis of commercial power generation, including work related to developing elements of fault tree, sequence tree, and event tree analyses. A statement of my qualifications and educational background l is set forth in Attachment A.
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in th: ::. : fi ld fr r the "Si'?errity f "cch st . I om a doctoral sm.didate f Berkel?Y !" th? fibld of :ncrgy i . aad rasauzca . "y :::::t "crk it ' terr 3 A t= fcca: 2 :n pr:5: bill:ti: ::::::: nt:-
' etzt: :nt of mp q::12 ica-ti:n: 1: ::t f:rth ir 'ttich ent 9.
My name is Gregory Minor. I am founder and vice president of MMB Technical Associates. I have 24 years of experience in the nuclear industry, including 16 years with the General Electric Nuclear Energy Division and 9 years as a consultant with MHB. A copy of my qualifica-tions has been submitted with other testimony. My educational background is in electrical engineer-ing in which I received a B.S. degree at the University of California , Berkeley and a M.S. degree from Stanford. My work with General Electric included the design, l testing, qualification and pre-operational testing of i safety eouipment and control rooms for use in nuclear l l power plants. l l As a consultant for MHB Technical Associates I have l participated in numerous technical reviews and analyses of l nuclear plant safety for government, public interest, and l l I t 1
private organizations. My work has included project coordination for a PRA study on the Barseback IIuclear Plant in Sweden, and involvement in the performance or analysis of several probabilistic consequence models re-lated to emergency planning for nuclear- plants in the United States. In addition, I have participated through review, analyses, and testifying in many licensing hear-ings for nuclear power plants in the United States and abroad. O. What is the purpose of this testimony? A. The purpose of this testimony is to address the question whether operation of the Shoreham plant at up to 5 percent power, under the AC power system proposed by LILCO in its Supplemental Motion for Low Power Operating License (the
" alternate" system), would be as safe as operation at up to 5 percent power with three fully qualified on-site emergency diesel generators, as described in the Shoreham FSAR (a " normal" system). In our opinion, operation with LILCO's alternate proposed system would not be as safe as operation with a normal system. .
C. Generally, on what do you base your opinion'
A. We have assembled and reviewed documentation that enabled us to compare the proposed LILCO alternate AC power system
-and its components, with the qualified on-site AC power system described in the Shoreham FSAP and its components, in particular, those systems which affect their capability to deliver, and sustain the delivery of, AC power to essential emergency loads. A dc;criptica cf ;k. Lov
;y;tc. : i: : ntain d in *.tta:PT:nt C '.;r;tc. We then performed a quantitative comparison of the probability of Shoreham reaching a state of core vulnerability (as .
defined by LILCO's contractor Science Applications, Inc. in Probabilistic Fisk Assessments for the Shoreham plant) due to loss of offsite power, during operation at five percent power, assuming operation with the alternate system and assuming operation with the originally proposed qualified on-site power system. l 0 How does the quantitative comparison you just described relate to the relative safety of the two systems? i A. The comparison of calculated frequencies of the.Shoreham plant reaching a state of core vulnerability due to a loss
. of of fsite power, given each of the two AC power systems, provides a cuantitative measure of the two systems' l
l l l .
relative safety in terms of the overall operation of the- l The fact that the cal- I plant at up to five percent power. culated probability of core vulnerability given operation with the alternate system is substantially greater than the corresponding probability given the normal system dem-onstrates that operation with the alternate system is quantifiably less safe than operation with the normal system. Q. Please describe briefly the two AC power systems you com-pared. l A. The proposed alternate system's major components include [ four General Motors EMD, mobile outdoor-type diesel repowered generators ( "EMDs") , and a 20-MW refurbished Pratt and Whitney gas turbine. The EMDs as well as the ' gas turbine were used (prior to their relocation to ' Shoreham) as peaking units for several years. Touuuwol
- det:il: cf thi: ;:n:::ticr equierent cr' cf'th: cupp:rting ci::tric f:cic:: ::n to f our ' ir T:ble C1 cf '.tt:c57. nt C.
i. ThC [rCFC :i :CCfijCr:Ibar b: d:pb Ici Dy Ih: lbE: db 37 " , in Ti,ms 02 of Attach :nt C. T'. : g::gr:phic:1 layout Of Lo mes e, o3mir .m ut i.; chcun in rigur 01. Th: prccedur : for ::t: ring pcuar cia th: ;;r turbin: ;' eth: C"C: cr I . d:: Crit:$ in I : tion 2.1.1.2. O f AL L;CI . nt O. m * .-,,-- --~,~----.-we.
. - - - , - . . 7,.,.m-- ,,-,.,,,,--...-~_,.,,-,,.,-,2 -mm__,-...+_y,.,_,__,m._m... . , . . ,,--w
m J 7 The normal. system consists of a set of three , , self-contained and operationally independent diesel gener-ators manufactured by Transamerica DeLaval Inc. ("TDIs"). T::?nic:1 d:tcil: of the TDI? ca" he f0""' i" " tian 2.1.2.1 cf ?.tt;;ha nt C :nd in.T : tim ny ;f C. Oenuis Cicy i
- t 21. Or ich lf Of S f felh C:unty ' r:q:rding C"O dica 4 gancr:ter: :nd th 20 "" g : turbin:. Sp::ific;ti:n; for ther ::=p n:nt: ::12ted t Oper: tier Of.th: TDT; cr 01:o licted in T; tic C1. The : nfigur ti:n Of th: . rm ;'l systc; i: ;h un in "igur Ci of ?tt;;P;;nt C. The operation of the TDIs is automatic.
O. Please describe the process you used in analyzing the probability of Shoreham reaching a state of core vulnera-bility during operation at five percent power under each system. A. Recently,, at LILCO's request, Science Applications, In-corporated ("SAI") and Delian Corporation performed a l l Probabilistic Risk Assessment for Shoreham operation at 5 percent power. "Probabilistic Fisk Assessment, Shoreham Nuclear Power Station, Low Power Operation uo to 5% of Full Power," by Delian Corporation and Science Applica-i> tions, Incorporated, Draft, May 1984 (hereinafter, "SAI l i l' ~6-l t
, , - - . .- - , . . , , - - . - . - , . . , _ . - . - . , , - n ..- ..- - -...... - ._, .-----.- .---.. - - . - . ,
i e ,
# Low Power PRA"). Our basic approach in performing our quantitative analysis of core vulnerability probabilities
;y was to use the structure and methodology used by SAI in
~
performing its assessment for LILCO. We used that method-4 :n ology to' produce two. estimates of the probability of
- reaching core vulnerability due to a loss of offsite power transient at Shoreham for operation at 5 percent power.
One estimate assumed that the TDIs, as described in the FSAR, were fully operational; and the other assumed that the EMDs and the gas turbine were operational in place of the TDIs. We decided to produce these two estimates for purposes of comparison, because the potential for reaching a state of core vulnerability is a key measure of whether operation of the Shoreham plant at 5 percent power with the alternate AC power configuration prcposed by LILCO would be as . safe as 5 percent power operation with fully qualified onsite diesel generators. Our principal data sources in deriving these two l estinates of core vulnerable probability were the SAI Low . I Power PRA and information from the Probabilistic Risk As-sessment dated June 24, 1983, also performed by SAI for LILCO. " Final Report, Probabilistic Risk Assessment, Shoreham Nuclear Power Station," Science Application f a
~
~'
l<
~ Incorporated, June 24, 1984 (hereinafter, "SAI 1983 PRA").
The latter source was used primarily to derive reliability figures relating to the operation of the TDIs.
. We used the SAI data in performing our analysis for several reasons. First, we did not have sufficient time to derive all the necessary data independently. Second, the approach and methodology used by SAI in its PRAs seemed generally reasonable, and in our professional judg-ment, the SAI analyses were competently performed and its results, in general, were reasonable and accurate. Third, we believe that since SAI acquired much of the data it used in its analysis from LILCO, it is reasonable to as-sume that the underlying factual data are likely accept-able to LILCO, thus reducing the chance of controversy regarding such underlying data. We used the SAI data, however, recognizing that in our opinion, not all the as-sumptions incorporated into the SAI analyses vare as con-servative or as appropriate as they should ha're been. At-tachment E sets forth certain adjustments that we believe would make SAI's estimates of core vulne'rability probabilities at Shorehan more realistic.
_q-
I l l I Core vulnerability can be produced by a number of initiating events. We limited our analysis to core vul- q l nerability f~ollowing loss of offsite power because, in the l SAI analysis, that was the only source of core vulnerabil-ity affected by the differing AC power configurations now at issue. In its Low Power PRA, SAI assumed that the EMDs and the gas turbine comprised the onsite emergency AC power system, and then investigated five types of accident se-quences, each involving a unique time within which core vulnerability was reached after a loss of offsite power. The probabilities of core vulnerability derived by SAI are contained in Table 3.1. 3 of the SAI Low Power PRA. We performed a comparable analysis, using the same methodolo-gy as SAI, but assuming that the emergency onsite AC power system was comorised solely of operational TDIs. We ob-tained the necessary data to perform the TDI event tree analysis from the SAI 1983 PRA. The result of SAI's cal- 2 cu.ations assuming the EMDs and the gas turbine provided emergency power, and of our calculations assuming the TDIs provided emergency power, are set forth in Table 1.1/ The 1/ We believe, based on our review of the SAI Low Power PRA, that S AI did not consider the possibility of repairing the (Footnote cont'd next page) 9-
.- _ . ~ . - . . . . . - , _ . . . , . . , _ . _ , . _ . . . _. . . . , , , _ . _ , - , , , _ , . .
TABLE 1 COMPARISON OF CORE VULNERABILITY FREQUENCY FOR LOSS OF OFFSITE POWER TRANSIENT FOR NORMAL AND ALTERNATT AC POWER SOURCES Frequency Loss of Off-(per Rx Yr); Frequency Time to using EMD (per RX Yr. ) ; site Power Sequence Core diesels and using TOI Type vulnerable gas turbine diesels 2 days 1.0E-7 5.lE-9 Type 1. 30 hours 3.2E-7 2.3E-8 Type 2 8.lE-7 1.3E-7 Type 3 3 hours. I 10 hours 5.9E-7 7.0E-8 Type 4 2.lE-7 l Type 5 7.5 hours 1.5E-6 00TAL 3.3E-6 0.44E-6 Note: - Column totals may not exactly equal the sum of the figures in each coltmn due to rounding. l e 4 r e yv-~-- vwy .-e-r-,-e-v- -vw w y -..- -,,w r,w,w-,w,,...,r---,--,,,---....y~w-. . - . ..-. . - --,,-,~.w--- ---,-------m---,--* --..---,w. . - - * -
event trees which form the bases for the frequencies in Table 1 are Attachment D. Q. What were your conclusions? A. As shownaan Table 1, the cal.culated probability of core vulnerability due to loss of offsite power, assuming I LILCO's alternate AC power configuration is in place (EMDs and gas turbine) is 3.3 E-6; assuming the normal configu-ration (TDIs) is in place, it is 0.44 E-6. This means that assuming there is a loss of offsite power during operation of the Shoreham plant at 5 percent power, it is' j l a more than seven times as likely that such an event would ; , lead to core vulnerability under the alternate system than under the normal system. It also means that the likeli-hood of the Shoreham plant reaching a core vulnerable condition due to loss of offsite power is over seven times greater under the alternate configuration than under the L (Footnote cont'd from previous page) EMDs or gas turbine if they failed. Accordingly, in deriving the frequencies in Table 1, we used values for the TDIs that also assumed no repairs if they failed. Be-cause there is a possibility, however, that either the TDIs or the EMDs and gas turbine could be repaired follow-ing a failure, we also performed a sensitivity study and compared calculated core vulnerable frequencies assuming such repairs. See Attachment E.
normal configuration. Furthermore, assuming the accuracy of SAI's estimate of 1.6 E-6 for the annual frequency of core vulnerability from all other initiating events during 5 percent opwration (SAI Low Power PRA at Table 4-4-1), 4 the likelihood that the Shoreham plant would experience an event leading to core vulnerability during 5 percent operation is approximately 2-1/2 times greater under the alternate configuration than it is under the normal con-figuration. We recognize that uncertainties exist in each of the core vulnerability estimates set forth in Table 1. How-ever, we believe that the uncertainties are comparable in the two estimates and that the existence of the uncertainties does not invalidate either the comparison or our conclusions. In our opinion the comparison set forth in Table 1 demonstrates that operation of the Shoreham plant with the alternate AC power configuration is not as safe as operation with a fully qualified source of emer-gency power. .. Did you perform any additional analyses or sensitivity
~
O. studies?
htNM A. A Ye s . We performed a sensitivity study to assess the re- IE duction in core vulnerability attributable to the possi-bility of repairing the TDI diesels and the EMDs and gas turbine following their failure. W'e also analyzed the effect _ of certain adjustments to the SAI probabilities of offsite power restoration and the frequency of loss of offsite power events at Shoreham, which we believe make those probabilities more realistic. These analyses are described in Attacht. tent E. O. Do the results of your sensitivity studies cause you to modify your conclusions regarding the relative probability of core vulnerability due to loss of offsite power given the alternate as compared to the normal Shoreham emergency power system? (.Weakeruax) A.b No. Our sensitivity studies confirm our conclusion that the probability of core vulnerability due to loss of of fsite power transient, assuming use of the alternate system, is higher than with the use of the normal configu-ration. The precise difference in probability, though l l uncertain, is sufficiently large to conclude that low c 4 power operation with the alternate configuration would not i be as safe as with the normal configuration. , 12 -
. - . - . - - - = .
e 9 D ATTACHMENT A 9
ATTACHMENT A . _ _ _ hSERASierro Energy and Risk Assessment,Inc. _ _ _ _ ._. R0ERT K. EATERWAX, S. EXPERIENCE: Jan. 1981 - Present President, Sierra Energy and Risk Assessment, Inc. Sacramento, California July 1980 - June 1981 Visiting Scientist, Energy and Resources Group, University of California, Berkeley July 1977 - December 1980 Chief Energy Forecaster, California Energy Comission, Sacamento, California Jan.1977 - June 1977 Staff Scientist, Science Applications, Inc. Palo Alto, California May 1974 - Jan. 1977 Staff Scientist, School of Engineering Princeton University, Princeton, New Jersey Jan. 1969 - April 1974 System Safety Supervisor, McDonnell Douglas Aeronautics Company, Huntington Beach, California As the founder and Chief Executive Officer of Sierra Energy & Risk Assessment, Inc. (SERA), Mr. Weatherwax is presently involved in the twin topics of (1) risk assessment and comparison, and associated cost benefit analysis, and (2) energy demand and supply assessment, and policy evaluation. He has had fifteen years of experience in nuclear safety analysis of commercial power generation and isotope power systems for space application. He has worked broadly in the area of nuclear fuel cycle risk assessment, and in reliability and failure mode assessment of complex systems. He has contributed to the original development of elements of fault tree, sequence tree (i.e., FAST), and event tree analyses, and has applied these methods to light-water. nuclear power plants, nuclear fuel cycles, radiciosotope thermal generators, strategic weapons systems and launch vehicles. In an American Physical Society meeting, Mr. Weatherwax debated Dr. Norman Rassmussin on the merits of the Reactor Safety Study, WAS,H-1400 (to which he was the major contributor). He is an engineer by formal education with a minor in econcmics and has applied tnese disciplines in numerous systems engineering and evaluation efforts, particularly related to energy demand forecasting and policy assessment during the last several years. As a McDonnell Douglas Astronautics Company (MDAC) employee, Mr. Weatherwax was principal author of a PSAR for the NASA 50 kWe space station power system. He later was manager for Environmental Impact and Risk Assessment on the MDAC team selected by the Air Force Weapons Laboratory (AFWL) to perform safety analyses of LES 8/9 and Viking missions. Af ter leaving MDAC he continued as a consultant to MDAC, and subsequently became a consultant to Teledyne Energy Systems in their support of the AFWL's space nuclear safety responsibilities.
SERA SIerro Energy and Risk Assessrnent,Inc. Robert K. Weatherwax, Jr. , Resume Continued i Mr. Weatherwax has perfonned energy and risk analysis of fusion systems and nuclear r: actor designs. At Princeton University, he modeled performance and cost proper-ties of T0XAMAK fusion reactor concepts and associated power conversion technologies CIRCA 2000. Mr. Weatherwax managed the risk analysis of the Hanford (nuclear) Reservation Purex plant. He also managed the initiation of the risk analysis of a l Swedish PWR under Swedish Government sponsorship. More recently, he has reviewed l and evaluated the probabilistic risk assessments of the Indian Point and proposed l Limerick light-water reactor power plants for the Union of Concerned Scientists and l the Limerick Ecology Action Comittee, respectively. In 1983, Mr. Weatherwax i testified before the Indian Point Atomic Safety and Licensing Board regarding the probabilistic risk assessment of the Indian Point power plant. l Mr. Weatherwax's current research and development interests in the area of probabi-l ' listic risk assessment focus on the adequacy of existing fault-tree and event-tree I methodologies,for estimating low-probability events and representation of uncer-tainties in risk / benefit analysis. He is now involved in an AFWL project reviewing 1 l the probabil.istic risk assessment of the space shuttle / Galileo - International Solar ' Polar missions. A list of risk assessment studies authored or contributed to by l Mr. Weatherwax is appended to this resume, Mr. Weathervax's experience in energy forecasting includes work done at Princeton University, UC Berkeley and as Chief Energy Forecaster for the CEC. During this l time, he performed research involving end-use, microeconomic energy demand forecast-l ing models and implementation of data bases to various end-use forecasting models. He developed the first utility service area version of a residential end-use energy demand forecasting model and associated load shape forecasting model. As the Chief Energy Forecaster, he was responsible for forecasting electricity and natural gas requirements and peak loads for utility service areas for use in determining the l' need for power plants within California. Duties included technical direction of others in performing development and implementation of state-of-the-art microeconomic end-use models of energy consumption by fuel type and electric peak load by economic sector by utility service area. Other duties involved evaluation of cost effective-ness of conservation and alternative energy options and their potential energy impact, and management of twenty-five post-graduate level professionals. 1 i l i I l . i
~ ~
_ hSERA Sletro Energy and Risk Assessment,Inc. ROBERT K. WEATHERWAX BIBLIOGRAPHY Selected reports and analyses authored or coauthored by Mr. Weatherwax in the field of risk assessment include: (With E. William Colglazier) Review of Shuttle / Centaur Failure Probability Estimates for Soace Nuclear Mission Acolications, Sierra Energy and Risk Assess-ment, Inc., Draf t Report for Telecyne Energy Systems, SERA No. 83-57, June "The 236U92 Penalty for Recycled Uranium", under publi-(With E. W. Colglazier) cation review, Annals of Nuclear Eneroy. Probabilistic Investment Decision Analysis Model, Sierra Energy and Risk Assessment, Inc., Report for the MCR Geotnennal Corporation, SERA No. 82-13, April 1982.
"Consnents on Assessment of Accidental Pateways, Subtask 0 Report (Draft), A. O. Littl Inc dated February 1978", for Office of Radiation Programs, EPA, July 12, 1978.
Nuclear Safety Analysis Methodology for RTG Eouipoed Satellite Launches, MDC G McDonnell Douglas Astronautics Company, Huntington Beach, California, May 1976. Nuclear Fusion Systems Analysis Research, AMS Report No.1250, Princeton Univer October 1975. Its Virtues and Limitations",
"Probabilistic Fission Power Plant Risk Analysis:
presented as an invited paper at the American Physical Society General Meeting April 1975, and published in Bulletin of the Atomic Scientists, September 1975. probabilistic Risk Analysis of Nuclear Systems, Princeton University Seminar, May 1975. (With C. Wildon, et al.) Launch Vehicle Reliability Considerations for Nuclear Safety Assessment, MOC G5983, McDonnell Douglas Astronautics Company, Hunti California, April 1975. (With R. Luna, et al.) Site Defense Safety Analysis and Hazard Evaluation Report, , MDC G4885, McDonnel Douglas Astronautics Company, Huntington Beach, California, I October 1973.
" Applications of Multi-Phase Fault Tree Analysis", pres 1973.
"A Comparison of Fault Tree Quantification Techniques", presented to Sysl Society Symposium, University of Southern California, April 1972.
Preliminary Safety Analysis Report, Volumes 1, 3, anci (With R. L. Gerva'is , et al . ) 5 (NASA Space Station 50 KW isotope and reactor power supplies ! Douglas Astronautics Company Huntington Beach, California, January 1971.
e- , S C L P - to l ATTACHMENT D
on-saw woe 6e eesas - .. s,. c
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. = o .
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0.6 0.3 1'0 ' l.0 '.llE-7
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0.03 1.0 1 0.1 .33E-10
.lE-3 0.7
.15E-3
{ 0.7 *25 1.0 1.0 .27E-11
.062 !
l
- 0.3 0.03 1.0 '
- 0.1 ! .23E-8
{ ,, .999 i
.99 ,04 +
.25 i 0.3 1.0 ,
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.04 i t .25 '
1*0 0,7 i 1.0 i .18E-10 0.3 0.03 l l 1.0 ,g 1
, ,1gg_7 i
Total Cumulative Value = 1.0E-7 Entry Conditions Sequence Type 1: LOSP; Isolation: Reactor Scrammed: Primary System Intact; Coolant Injection Available through 10 hours via HPCI/RCIC; reactor may be depressurized to 150 psia, l EVENT TREE D-1 (Table 1, Column 3)
. - , . - . ~ - - - - - . , - - , _ - , - , - - - ._--.--,-
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- =
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+
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0.8 O.2 .14E-8
.5E-2
.99905 0.7
.15E-3.0 96 0.M 0.04 ,
0.25 ' ' 0.7 ' i*o ' l.0 t .55E-l' 0.3 d~ 0.03 o,g 1.0 ' O2 i .iiE-7 i Total Cumulative Value = 3.2E-7 Entry Conditions Secuence Type 2: LOSP; Isolation Reactor Scram.,ed; - Reactor Integrity Intact; Coolant
!!akeup Available 0-4 {ourst Reactor may be decressurized to 150 psia.
EVENT TREE D-2 (Table 1, Column 3)
9uus .se e ca sg y ",,7, [g*,,,' [w d ... o.s.s . .
- .. - .s gussom.seessa a.ge si .le g,= ,g,,,
- u a tan se Os Q* W D 8 3 y m
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! r 0.75 0.96
*99 o,o4 0.75 1.0 0.25 0.3 .39E-6
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0.03 ' 0-3 i 1*0 ,sgr_g 0.25 o,$
.99985 0.7 '.15E-3 0.96 0 75 0.04 '
0.25 O.7 j 1,o ' 1.0 e i .96r-tc
- 0.97 0.3 0.03 05 1.0 i o.3 i .4is-6 i
Total Cumulative Value = 8.1E-7 Entry Conditions Sequence Type 3: LOSP; Isolation Reactor Scrammed; SORV, LOCA or ADSt. no Coolant :takeup Availabler Reactor Deoressurized to. Less than 65 nsia. EVENT TREE D-3 (Table 1, Column 3) sv - - - - , , - - , , - - _ , . , . ,. , , , , , _ _ _
usw
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0.7 i t*o ',6 .
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Total Cumulative Value = $.9E-7 Entry Conditions Sequence Type 4: 1.0SP; CoolantIsolation; InjectionSORV.Available Initially. i 4 I i EVENT TREE D-4 (Table 1, Column 3) 1 l l r' i
noso.., .ran- iw.wis on-wee uvuit e cree - awaga nesa
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- e. o. ' o- c'" ' '
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- 0.7
- t .15E-3 i l . 0.04 i i .25 1 i
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- 1.0 . 2']i-i
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Total Cu::ulative Value = 1.5I - In:rv Condi: ions f or S equence Type 5: 1.0SP; Isolation; no ini:ial Coolant Makeup; Procedural Depressurizacion
! e I
i EVENT TREE D-5 (Table 1, Column 3) l l L _ . - . - . . - . - - . - . . - - - - . - . . _ . . . . _ _ - - -
' e s
- N g 7 ague mesnag63 auss6aens aument aumenAe64
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'^i d.E .
.LERet ,_g
.168 f9 A1 .499.g2
.9062 0.1 a.e
.262 l
i ai l .:. _ i _ l l Total O==ilative Value = 5.lE-9 l Entry Conditions Sequence Type 1: IDSP, Isolation; Reactor Scramned; Primary System Intact; Coolant Injection Available through 10 hours via HPCI/RCIC; reactor may be depressurized to 150 psia.
- Does not reflect repair.
EVDTI TREE D-6 (Tablo 1, Colum 4) L *
- _ __ _ --~,.. _ _ _._ _ _____.
LOSP
- macoveny unsN encaup ort-sit t Ort stis
- s ent wasta stout Net M8GM PRES- sunicurano switcMyano senwpowen awn:La stE sw it c t CN tat outwi v or ot t -
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.995
.9962
'*3 r1Ss-1
.30E-2
.2 .175-1
.5r-2
'. .999t5 0.7 .9642
.15E-3
.6
.38E-2 0.7 .2 .42 *11
.sss2 0.3
.8
* ,30E-2
.2 .11E-7 l Total Cumulative Value = 2.8E-8
' Entry Con'ditions Sequence Type 2: LOSP; Isolation; Reactor ! Scrammed; Reactor Integrity . Intact; Coolant Makeup Available 0-4 Hours; Reactor may be depressurized to 150 psia.
- Does not reflect repair i
l l EVENT TREE D-7 (Table 1, Column 4) i 1
LasP+ae atCOvtRY MatN S.CMUP Of f-Sitt Os t Si tS
- Fiat WaltR $40UENCE SwtTCMv4AD SwitCMyano seMwpowtm avaitaatt opsjt ct p gg OF OF F -
avait a.ition rsit.out so Co. wc,v seit no.En avan .te avaitante avaitant e
, , , , out wt Rasi t R Ma es Os O r 3U 0.75
.9962 0.3 0.5
.52E-3 .
.38E-2 0.5 .74E-7 0.25 .99985 )
l 0.7 .9962
.15E-3 O.5
.30E-2 0.7 .
0.5 .16E-10
.9962 0.3 0.5
.30E-2 0.5 .52E-7 Total Cumulative Value = 1.3E-7 Entry Conditions Sequence Type 3: LOSP; Isolation; Reactor Scrammed; SORV, LOCA or ADS; i
l no coolant Makeup Available; Reactor Depressurized to - Less than 65 psia.
- Do:s not reflect repair l
EVENT TREE D-8 (Table 1, Column 4) l t t
OttSLLS* p sRL watL R St out NCE hs AIN SAC 9 TUP Of f-Sa f f INJE CitON FfE 04KMC F LOSP* ptCovt97 SmTCHvARO emyPOWER AW A LL A EL L FOR CORE Of Of t a SuntCmvam0 Ava L AsLE
**GM P8ES- avALAsLg AvA L AsLE Ava:LAsLE vuLNERastt IN ACisON satt powgn w es ca m se m O F I (U R 0.54
.9962
*I 0.9
.20E-2 .30E-2
.3 41E-7 0.06
.99905 y o,7 .9962
.15E-3 .7
* .30E-2
,3 .10E-10
.9962 7
0.3
.30E-2
.3 .29E-7 Total Cumulative Value = 7.0E-8 Entry Conditions Sequence Type 4: LOSP; Isolation; SORV; Coolant Injection Available Initially.
$Does not reflect repair l
EVENT TREE D-9 l (Table 1. Column 4)
I DIESE LS FIRE WATER SECAlt hC.E MAIN SACmur OFF-Saff F AC JUI hC V LOeP 3 NO RECOVEnv W WPOWER AwAIL A BLE is* JECT ON Of Of f - SwifCMyARO SwlTCMVARO Await AeLE
@ MS. astE mm AmeLAhE AvAILAeLE AwAILAst E te8JEC1 EON O F se On w a has 0.87
.9962
.218-2
.6
.0030
.4 .12E-6 0.13 *
.99995 o.7 9962
.15E-3
.6
.0030
,4 .312-10 n.7
.9962 0.3
.6
.0030
,.4 .81E-1 Total Cumulative Value = 2.lE-7 Entry Conditions for Sequence Type 5: LOSP; Isolation; no initial Coolant Makeup; Procedural Depressurization.
- Does not reflect repair EVENT TREE D-10
SC LP-ba ATTACHMENT E L
F' , Attachment E SENSITIVITY STUDIES AND ADJUSTMENTS TO SAI METHODOLOGY AND DATA Scme of the data and assumptions used by SAI in per-forming its Low Power PRA for LILCO could be improved or made more accurate. The'two most significant items are (1) the frequency of occurrence of the loss of offsite power transient at the Shoreham facility, and (2) the as-sumed means of restoring offsite power via the 69 KV switchyard. It also appears that slight changes are nec-essary in the probability of restoring power following a loss of offsite power and in the conditional availability of the 138 KV switchyard following the occurrence of a loss of offsite power. We have recalculated the frequencies of core vulnerable conditions due to loss of of fsite power, as set forth in Table 1 of our testimony, I using corrected data as described below. First, we used a loss of offsite power frequency of 0.25 events per year instead of .082 events por year as was used by SAI in both the Low Power PRA and its 1983 E-1 L
- p. ,
+
PRA. SAI's loss of offsite power frequency value is based on data concerning only the LILCO grid. (SAI 1983 PRA,
~
page 3-102). . Muss , its value of .082/ year does not take into account the probability of failures within the Shoreham switchyard resulting in loss of offsite power. In our opinion, the failure to account for such failures makes the SAI value unrealistically low. The .25/ year frequency of loss of offsite power, which we believe is more realistic, is from a Brookhaven National Laboratory assessment of the frequency of loss of offsite power for the nuclear reactors found in the
~ Reliability Council region to which LILCO belongs. See Table E-1. We consider this figure to be conservative, but more realistic than SAI's, because it takes into account the contribution to losses of offsite power from failures in the switchyards of nuclear power plants. Such failures are a major contributor to loss of offsite power events. Although we believe that a value even higher than the .25 figure might be appropriate for a plant such as shoreham which will be operated at low power by relatively inexperienced operating staff using equipment subject to break-in type failures, we did not increase the Brookhaven frequency in performing our calculation.
E-2
-rf , 1 Second', our recalculation also corrected what we believe to be an error in the SAI model for offsite power availability. The SAI low power event tree for the loss of offsite- power transient takes into account the possi-bility that offsite power will be restored at different times after the transient, with varying probabilities. SAI also assumes, however, availability of offsite 69 KV power with a probability'of 0.99985, after the occurrence of the loss of offsite power transient. We believe this second assumption is improper, and amounts to double counting, because the probability of restoring offsite 69 KV power is already included in the event tree in the time varying probabilities for restor'.ng of fsite power. We have eliminated this double counting in our recalculation. The final major change we made was to consider the possibility of repairing the gas turbine and the EMDs fol-lowing a failure. The SAI Low Power PRA did not discuss the possibility of repairing the EMDs and gas turbine. Thus, to the best of our knowledge, the values in Table 1 of our testimony reflect comparable assumptions of no repairs for both the EMDs and gas turbine, and the TDIs. If the SAI Low Power PRA did include repairs of the EMDs and gas turbine, then the difference between the core
. E-3
p-vulnerable frequencies for- the TDIs and the EMDs and gas turbine is understated in Table 1 to our testimony, be-cause adding the.repairability assumption to the TDI values would further reduce the probability of reaching a core vulnerable condition. We took values from the SAI 1983 PRA to determine the core vulnerable frequencies assuming the TDIs could be repaired. To be conservative, we used the same TDI repair i values used by SAI in our EMD and gas turbine event trees , to determine core vulnerable frequencies for the alternate system. The results of our recalculations are summarized in Table E-2. Increasing the frequency of loss of offsite power increases the estimated frequency of core vulnera-bility due to loss of offsite power by an equal factor of about 3 for both the alternate and the normal AC power systems. Thus, the impact of this adjustment is=only in the overall core vulnerable frequency, and the adjustment does not affect the frequency for one system relative to the other. The elimination of redundant consideration of offsite power restoration results in a greater increase in the probability of core vulnerability for the alternate configuration than for the normal configuration. This E-4
7 - would reflect the greater dependency of the alternative system on the 69 KV switchyard availability. Explicitly considering repair of the gas t'urbine and EMDs reduces the estimated probability of core vulnerabil-
'ity due to loss of offsite power for the alternate system.
The TDI analysis showed a comparable reduction in core. vulnerable frequency when repairability was included. This is expected because the system components might be returned to operation even though they may ha.ve initially failed to operate. Combining the corrections in-data and methodology de-scribed above, and assuming the possibility of repair for both the alternti a and normal systems, the probability of core vulnerability due to' loss of offsite power, is still about a factor of 4 higher for the alternate system. Fur-thermore, assuming the accuracy of SAI's estimate of 1.6
'E-6 for the annual frequency of core vulnerability from all other initiating events during 5 percent operation (SAI 1983 PRA'at Table 4-4-1), the likelihood that the l
l- Shoreham plant would experience an event leading to core vulnerability during 5 percent operation is approximately > 2.8 times greater under the alternate configuration than it is under the normal configuration. l
^
E-5 f
?
TABLE E-1 PLANT-SPECIFIC POSTERIOR PROBABILITY FOR THE FREQUENCY OF THE LOOP (Events Per Year) RELIABILITY COUNCIL - NPCC , PLANTS IN SITE N T NEAN 5 PERC' 55 PERC 95 PERC
- 1. Fitzpatrick 2 5.55 2.0E;01 9.6E-02 2*.4E00i 5.4E001
- 2. cinna 3 10.57 2.6E401 1.0E-01 2'.2E-05 4.6EE01
- 3. Iladdam Neck 5 13.72 3.0E101 1.3E-01 2'.7EE01 5.0E-01
- 4. Indian Point 2 & 3' 4 7,94 3.5E-01 i.4E-01 , 3*.6E-0j 6.2E101
- 5. Main Yankee 1 7.62 2.0E-0'1 5.3E-02 l'.7E40i 3.8E101
- 6. Hillstone 1&2 1 10.47 1.7E-01, 4.5E-02 1*.5EE01 3.2E101 ,
- 7. Nine Hiie Point 1 11.32 l'.6E-01 4.3E-02 1".4E101 3.1E-01
- 8. Pilgrim 4 7.96 3.5E-01 1.4E-01 3'.0E-01 6.2E-0) .
- 9. Vermonc Yankee 1 a.19 1.9E10'1 5.1E-02 1".6Eloi 3.7E401
- 10. Yankee Howe - 1 20.70 1.2EE01 2.9E-02 l'.0E-01 2.2E-01 1
AGGREGATE 23 104.04 2.5E-01 4.4E-02 1*.9EE01 5.8E-01 Source: I. A. Papazoglou et al, Bayes Analysis Under Population Variability With An Application to the Frequency of Loss of Offsite Power in Nuclear Plants, BNL Report, Feb., 1983.
..l TABLE E-2 REQUANTIFICATION OF SAI EVENT TREE FOR CORE VULNERABILITY DUE TO LOSS OF OFFSITE POWER TRANSIENT (Frequancy Per Reactor Year) l Gas TurDine/ maw Diesels TUI Diesels '
Type Non-Repairable Repairable Non-Repairable Repairable i 1 2.3E-5 1.0E-6 1.4E-6 6.4E-8 2 1.9E-5 1.7E-6 1.2E-5 1.1E-6 , 7.0E-7 3.5E-7
~
3 4.0E-6 2.0E-6 i 4 5.6E-6 1.3E-6 6.8E-7 1.6E-7 l-5 8.7E-6 2.6E-6 1.2E-6 3.6E-7 Sum 6.0E-5 .87E-5 1.6E-5 . 21E-5 i l - l Note: Column totals may not exactly. equal the sum of the figures f in each column due to rounding. l l l l
,-..ww,-. --y-.- -.-,,. -y, ,- ,+,.-...y ---}}