ML20115A157

Forwards Jacksonians United for Livable Energy Policies 840329 10CFR2.206 Petition Questioning NRC Personnel Conduct & Requesting Revocation of Low Power License.Draft Ltr Ack Receipt of Petition Encl for Signature

ML20115A157
Person / Time
Site:	Grand Gulf
Issue date:	04/17/1984
From:	Lieberman J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20115A155	List: ML20115A152 ML20115A157 ML20117D763 ML20117D993 ML20117E052 ML20117E068 ML20117E102 ML20117E130 ML20117E152 ML20117E185 ML20117E190 ML20117E199 ML20117E289 ML20117E298 ML20117E305 ML20117E326
References
FOIA-84-665 NUDOCS 8405140068
Download: ML20115A157 (8)

Text

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April 17,1994

!1EMORANDUM FOR:

Harold R. Denton, Director Office.of Nuclear Reactor Regulation

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James-Lieberman, Director and Chief. Counsel Regional Operations and Enforcement Division Office of the Executive Legal Director

SUBJECT:

10 CFR 2.206 PETITION CONCERNING GRAND GULF NUCLEAR STATION The attached petition from Jacksonians United for Livable Energy Policies has been referred.to the staff for treatment under 10 CFR 2.206. The peti-tioner asks.the Comission.to order the Mississippi Power and Light Com-pany to show cause why the low power license for Grand Gulf Nuclear Station,.

' Unit 1, should not be revoked and a stay of operation be issued. The

' petitioner bases its request on identified problems and discrepancies in the technical specifications and other aspects of the license as well as problems encountered with the Transamerica Delaval diesel generators. The petitioner would also have the Comission order remova'l of. Grand Gulf management responsible for the various problems at the plant and require implementation and verification of corrective actions for deviations from the requirements. The petition also raises questions about the propriety and effectiveness of NRC personnel's actions in dealing with Grand Gulf.

For this. reason, I am referring a copy of the petition to the Office of Inspector and Auditor for its use as appropriate.

I have enclosed for your use drafts of a letter of acknowledgement to the petitioner for your signature and a notice of receipt of the petition for publication in the Federal Register. The acknowledgement letter may need

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additional technical information in view of your proposed action to modify the license to correct some technical specification deficiencies.

In this regard, the acknowledgement letter should be prepared as soon as possible to coincide;as nearly as possible with issuance of your proposed order. As you-Lknow, we have been working with your staff in developing that order and will work with them in developing a final acknowledgement letter as well as the

final response to the petition.

1 CONTACT: Steve Burns, OELD 492-7268m, W-)$ /Ly @6%l c F r

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2-In reviewing the petition, you may wish to consider whether you need acditional information for the licensee to address those issues raised in the petition.

If you find that a response from the licensee would be helpful,-

we will assist you in drafting an appropriate demand for information pursuant to 10 CFR 50.54(f) ar.d Section 182 of the Atomic Energy Act.

Please place my office on concurrence and distribution for all correspondence related to the petition.

Janas Lieberman, Director and Chief Counsel Regional Operations and Enforcement Division Office of the Executive Legal Director

Enclosures:

as stated cc:

D. Eisenhut, NRR J. O'Reilly, RII E. Christenbury, OELD R. DeYoung, IE Distribution ROED rdg (P-84-05)

R0ED Sub EDO # 14329 Cunningham/Murray Hearing Attorney (M. Wagner) 2.206 chron Regional Counsel (B. Jones)

Burns chron Lieberman chron Cuoco info NRC Central ELD Rdg J. Axelrad RH/KC/SC info E. Adensam O

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Docket No. 50'-416 (10 CFR 2.206) lis. Cynthia Stewart Jacksonians United for Liveable Energy Policies Route 3, Box 314 - W Jackson, Mississippi 39213

Dear fis. Stewart:

This letter is sent to acknowledge receipt of your petition on behalf of the Jacksonians United for Liveable Energy Policies received by the Commission on April 10, 1984 Your petition requests that the Commission issue an order to flississippi Power and Light Company to show cause why the license for the Grand Gulf Nuclear Station, Unit 1, should not be revoked and a stay of operation should not be issued.

You base your petition primarily on discrepancies in technical specifications that have been found since issuance of the low' power license and on difficulties with diesel generators supplied by Transamerica Delaval in use at Grand Gulf Station. You also ask that the operating license be modified to remove responsible management -

personnel and to ensure implementation and verification of corrective actions associated with the technical specification discrepancies. Your petition has been referred to the staff for consideration in accordance with 10 CFR 2.206 of the Commission's regulations and, accordingly, appro-priate action will be taken on the petition within a reasonable time.

Your petition also raises questions concerning the, propriety and effective-ness of NRC personnel's actions related to Grand Gulf.

Although your request e

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for appointment of an " independent panel" to look into this issue is beyond the scope of relief normally conterplated under 10 CFR 2.206, a copy of your petition has been provided to the Office of Inspector and Auditor for its consideration'.

I would like to bring to your attention two matters relating to issues raised in your petition.

first, I have issued the enclosed order for the Grand Gulf Station which restricts conditions for operation of the plant in accordance with revised technical specifications that are intended to remove the signifi-cant discrepancies in existing specifications which would pose a potential hazard for low power operation. While the current license for Grand Gulf authorizes operation of power levels up to 5%, I have determined the public health, safety and interest require that operation be permitted only in accordance with the more restrictive technical specifications imposed by the order. Second, I enclose a copy of a safety evaluation report regarding the impact of the diesel generator problem on low power operation.

For the reasons described in the safety evaluation, I do not believe that it is necessary to suspend low power operation while the diesel generator problem is being addressed. Resolution of the diesel generator problems will be required before full power operation is authorized.

I also enclose for your information a copy of a' notice that is being forwarded to the Office of the Federal Register for publication.

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation cc: Mississippi Power &' Light Co.

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NUCLEAR REGULATORY C0fV11SSION

[ Docket No. 50-416]

filSSISSIPPI POWER AND LIGHT COMPANY, ET AL.

(Grand Gulf Nuclear Station, Unit 1)

Receipt of Pe:ition for Action Under 10 CFR 2.206 Notice is hereby given that by petition dated March 29, 1984, the Jacksonians United For Liveable Energy Policies has asked that the Commission order the Mississippi Power and Light Company, et al. to show cause why the license for Grand Gulf Nuclear Station, Unit 1, should not be revoked and a stay of operation not be issueo. The petitioner bases its request for relief on discrepancies discovered in technical specifi-cations since the issuance of the license in 1982 and on problems asso-ciated with the capabilities of diesel generators used at the plant which were designed by Transamerica Delaval Company. The petitioner also asks for modification of the license to remove management personnel ctre s

for problems at Grand Gulf and to ensure implementation and verteication of corrective actions for identified deviations from NRC requirements.

-The petition is being treated under 10 CFR 2.206 and, accordingly, appro-priate will be taken on the petition within a reasonable time.

Copies of the petition are available for public inspection in the Commission's Public Document Room at 1717 H Street, N.W., Washington, J

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D.C. 20555 and in the local public document room for the Grand Gulf

!;aclear Station at Dated at Bet'asda, tiaryland this day of April,1984.

FOR THE flVCLEAR REGULATORY C0t'.t1ISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation O

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FILE LOCATION Dexccutive omccion hSCfhPflON OEr~ icd O utuo O acroar O OTHER SPECIAL INSTRUCTIONS OR REMARKS

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2.206 - Show Cause Petition requesting,

revocation of low #di power license andl denial of a full power operating license for Grand Gulf Nuclear Station Unit 1 A' SkitaCO TO DATE INFORMATION ROUf tNG b[r$ninghamELD$.4/11/84_

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NRC SECRETARI AT t

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incoming:

Cynthia Stewart Jacksonians United for Livable Energy F rom.

Policies To: Co iesioners Date 3/29/84 Show Cause Pelition on TDI Generators, i

Subject:

i R:: questing Revocation of Low Power License and D:'nial of a Full Power Operating License (2.206)

Prepare reply for signature of:

O Cnairman O Commissioner

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• SUSPENSE: May 8, 1984 For appropriate action O For information i

f For recommendation Remarks: Cyc rnmi c c i onern. OGC. OPE. OPA. OCA.

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UNITED STATES OF AMERICA 0004,g",.

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NUCLEAR REGULATORY COM.'4ISSION N pU BEFORE THE C MMISSION R2:31 In the Matter of

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MISSISSIPPI POWER & LIGHT COMPANY, et al.

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SHOW CAUSE PETITION FROM JACRSONIANS UNITED FOR LIVABLE ENERGY POLICIES ON T. D. I, GENERATOPS, REQUESTING REVOCATION OF LOW POWER LICENSE AhT DENIAL OF A FULL POWER OPERATING LICENSE FOR GRAND GULF NUCLEAR STATION UNIT 1 I. INTRODUCTION 1.

Comes now Jacksonians United for Livable Energy Policies (hereinafter " Petitioner"'or.

" JULEP") to petition the Commissioners of the U. S. Nuclear Regulatory Commission (NRC),

pursuant to Title 10 of the Code of Federal Regulations, Section 2.206,to serve upon Mississippi Power and Light Company (" Licensee" or "MP&L") an order to show cause, pursuant to 10 C.F.R. 2.202(a), why the low power license for Grand Gulf Nuclear Station, Unit 1, should not be revoked, a stay of operation issued, the pending application for an operating license denied, and a proceeding initiated under 42 U.S.C. 2239(a).

II. DESCRIPTION OF PETITIONER 2.

JULEP is a public interest organization formed in 19'T9 to address issues of nuclear power, and utility rates and conduct. Members have testified at Atomic Safety and Licensing Board Panel hearings and environmental hearings on Grand Gulf and have written letters pro.

testing Grand Gulf to the NRC. Tne organization is currently involved in proceedings to challenge certain technical changes in the operating license for Grand Gulf, Unit 1.

Several members of JULEP live within 20 miles or less of Grand Gulf.

III. AUTHORITY 3.

Title 10. of the Code of Federal Regulations,2.206(a), establishes the right of the public to petition the Commission to institute a proceeding pursuant to 2.202(a) to modify, b

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. suspend, er revoke a license or for other relief. Such a peti: ion :nus: set.forth the factual basis and the relief recuested. The Commission may, pursuant to 10 C.F.R. 2.202(a), institute such a proceeding by senicing upon the licensee an crder to show cause.

IV. DISCRETIONARY HEARING 4.

The Atomic Energy Act of 1954 gives discretion to reuke, suspend, or modify the construction permit of an NRC licensee:

A license or construction permit may be revoked, suspended or modified in whole or in part, for any material false statement in the application for license or in the supplemental or other statement of fact required by the applicant, or because of conditions revea. led by the application for license or statement of fact or any report, record, inspection, or other means which would warrant the Commission to refuse to grant a license in an original application; or for failure to construct or operate a facility in accordance with the terms of the construction permit or license or the technical specifications in the application; or for the violation of or failure to observe any. of the terms and provisions of this chapter, or of any regu-lation of the Commission.

42 U.S.C. 2236. Notwithstanding the discretionary aspect of this statute,the NRC has a manda.

tory dut.y to exercise its authority when necessary and is required to determine that there will be adequate protection of the public health and safety. See Natural Resource Defense Council vs.

U. S. Nuclear Rerulatorv Commission,528 F. 2d 166 (2d Cir.1978). The Supreme Court has determined that th'e Atomic Energy Act mandates that "the public safety is the first,last and permanent consideration in any decision of... a license to operate a nuclear facility." Power Reactor Co. v. Electricians,367 U.S. 396,402 (1961), quoting In re Power Reactor Development fa,1 A.E.C.128,136 (1959).

5.

JULEP seeks consideration of whether the Licensee has met and will continue to meet the requirements of the Rules and Regulations of the NRC, and further, whether there exists.

reasonable assurance that continued low power operation, and issuance of a full power h_ cense to the Licensee,will not jeopardize the public health and safety.

6.

There is no existing forum to address the matters at issue. The operating license for Grand ' Gulf was uncontested. A request for hearing and petition to intervene filed at this stage pursuant to 10 C.F.R. 2.714 would be untimely. At the time the Operating License application for Grand Gulf, Unit 1, was noticed, JULEP did not represent affected members of the public, and was unable to contemplate an active role as intervenor.

7.

The lack of an existing forum does not alter the fact that a utility bears the burden of proof. As the Commission has stated:

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We think it ineluctable that a utihty must bear the burden of proving compliance with the Commission's safety regulations no: only at the beginning and at the end cf the nuclear licensing process -but,as in this case-when called upon at some interim ooint :o "show cause" why a cons: uction per.i: should not be lifted fcr unsde ecnst uction prac: ices.

Consumer Power Comeany (Midland Plant, Units 1 and 2), ALAB-315, 3 N.R.C.101,104 (1976). A petitiener need only provide the NRC staff with " sufficient reason"to look into the

, matter of revocation of a license, but is not required to assume the burden itself. Consolidated Edison Comeany of New York, et al. (Indian Point Units 1,2 and 3), CLI.75 8,2 N.R.C.173, 177 (1975). Public safety, as well as the right of the public to due process of law, dictate that this should be so.

8.

Regardless of the lack of an cristing forum, the public is entitled to a hearing in order to protect the public interest in its health and safety. As Scenic Hudson Preservation Conference

v. Federal Power Commission,354 F. 2d 608 (1965), demonstrates,the NRC is under an obliga-tion to consider all relevant information in an effort to protect the public interest, especially in

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an issue.cf this type where concern for public health and safety is so great.

9.

'A' petitioner, in requesting a show cause order, must show that " substantial health or safety issues [have] been raised." Indian Point, suora, at 177. Another test against which any request for a discretionary hearing must be judged is whether such a proceeding would serve any "useful purpose." Public Service Company of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), CLI-80-10,11 N.R.C. 438,443 (1980). In the instant case, the lack of inter-vention in the licensing of Grand Gulf notwithstanding, the matter of the operation of the plant is of great concern to residents of Mississippi. Enormous cost overruns, resulting predicted increases in utility rates, and a history of delays, management and technical difficulties,and the

' falsification of training data of employees at Grand Gulf have given rise to tremendousinterest and concern about the plant. As will be shown, the problems forming the base of this request point to an inevitability of harm to public health and safety. The understandable interest of the public can only be addressed in a public forum. The long history of problems has caused the public to lose faith in the regulatory process. Regulation of Grand Gulf, because of the lack of prior public intervention, has been conducted largely out of the public eye.

10. The "useful purpose" served by a discretionary hearing is the technical resolution of problems resulting in a greater degree of safety afforded to the public. Suspending orders can be used to remove a threat to the public health and safety. The primary test of "useful purpose"

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is based on what type of regulatory action best serv,es the public welfare.

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11. Given the Licensee's constant failures to meet regulations - indeed, its apparently deliberate breaking of regulations in the case of employee t-aining - and the enormous number of discrepancies between physical plant and speci'ications,it can only be concluded that neither the NRC nor the Licensee knows what has been constructed. The relief requested by the peti.

tiener, including 100% review of the design and as-built plant and an adjudicatory determination of both the quality of the Licensee's plant and management,is the only method of determining that operation of this facility will not pose a threat to the public health and safety. This,in essence, is a determination of the " inevitability of harm," based on the extent to which the Licensee has conformed to the NRC's regulations.

V. 10 C.F.R. SECTION 50, APPENDIX A, CRITERI A

12. Grand Gulf, Unit 1, received a low power license in June 1982. Discovery of a design flaw requiring modifications delayed completion of low power testing until late last year. In the NRC-conducted Systematic Assessment of Licensee Performance (SALP) annual Board reviews!'MP&L management has consistently scored poorly. Grand Gulf received a license despite the fact that approximately 200 technical specifications and 600' surveillance procedures were in error, despite the fact that the qualifications of operators were apparently faisified,and

.despite the fact that the drywell cooling system was inadequately designed and constructed.

Some of the erroneous surveillance procedures were submitted for equipment that does not~even exist at the plant. Some of the incorrect technical specifications were written for a different size and type containment building than the or.e at Grand Gulf. Crand Gulf, Unit 1,is the first U.S. boiling water reactor to use Mark III containment. MP&L has no previous nuclear experi-Until very recently, none of the operating staff had operated a commercial reactor. In ence.

light of all these factors, Grand Gulf should have received the strictest scrutiny by tee 3RC.

Hugh Thompson of the Office of Nuclear Reactor Regulation has admitted that neither staff nor applica.;t review' of the technical specifications was adequate (Inside NRC,' March 5,1984, p.9). Prior to licensing, the NRC sent MP&L a copy of technical specifications for a Mark II containment plant, expecting the licensee to review and adjust them to meet the actual physical plant. MP&L did not do this. NRC assumed that it had and issued a low powerlicense. None of the problems - the considerable discrepancies in technical specifications and surveillance procedures, the falsification of operator training data, a design flaw requiring modification -

were even discovered until after issuance of the license. No public hearing has been held on these s

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issues, ner was a prior public hearing held when the NRC agreed to waive certain technical recuirements in September 19SS. In spite of these problems, and consistent poor performance cf Licensee ma.agement, the NRC has repeatedly assred i:sef tha: corrective actions have been ini:iated which will resul: in the fulfillment of NRC regula: ions. Nothing in the existence or history of tl is plant justifies this excusing.-

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13. The Licensee has been, and continues to be, incapable cf meeting NRC reouirements,

' particularly Appendix A to 10 C.F.R. Section 50. Criterion 17 under IIin Appendix A states:

The onsite electric power supplies, including the batteries and the onsite electric distribution system, shall have sufficient independence, redundancy, and test-ability to perform their safety functions assuming a single failure."

VI. INADEQUATE ONSITE ELECTRIC DISTRIBUTION

14. Two of the three electrical generating engines at Grand Gulf are Model DSRV 16, supplied by Transamerica Delaval (TDI). These engines have experienced significant problems in completing the pre operational test program, have had several major failures, including a fuelline break wNich caused a fire, and many minor failures. The problems to date include:

3/81 Excessive turbocharger thrust bearing wear; 4/S1 Non-class lE motors supplied with EDG auxiliary system pumps; 11/81 Piston crown separation during operation; 1/82 Governor lube oil cooler located too high, creating possibility of trapping air in the system; 3/82 Air start sensing line not seismically supported; 3/82 Engine pneumatic logic improperly designed, creating possibility of prema-ture engine shutdown; 3/82 The crankcase cover capscrew failed, with head lodging in and shorting out the generator; 6/S2 Air starting valve capscrews replaced because they were too long for holes; 8/82 The flexible drive coupling materialincompatible with the operatag emiron-ment; 8/82 The latching relay failed during testing; 7/83 Air start ulve failures; S/83 High pressure fuelinjection line failed; S/83 Cracks in connecting push rod welds discovered;

-c 9/S3 The fuel oilline failed, causing a mejor fire; 9/83 Unqualified instrument cable; 10/S3 Fuel oil leak; 10/83 Cracked push rod weld; 1983 Turbocharger mounting bolt failures; 1983 Cracked jacket water welds; 1983 Turbocharger vibration; 12/83 Cylinder head cracks; 12/83 Cracks in piston skirts in Division II EDG; During EDG Installation Cylinder head cracks.

15. The long history of problems with TDI generators at Grand Gulf and other plants (see Attachment 1) demonstrates that they cannot be depended upon to function when needed.

This leaves only one dependable source of electric power in the event of an emergency. This does not meet the redundancy required by the NRC.

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,, 16. The Licensee prcposes to jury rig gas turbines to overccme the problem (see Attach-ment 2). At the February 29 NRC Commission meeting. MP&L inicated that these gas turbines would require 10-15 minuter to come to gewer as cpposed to the '.0-15 seco :cs now requi-ed for the diesel generators (February 29 Briefing on the Status of Grand Gulf before the NRC, page IS). 'Fhis long delay is totally unacceptable in the course of an accident.

17. MP&L has proposed to switch the third ncn-TDI divel generator, which is dedicated to the High Pressure Core Spray system (HPCS), over to carry other loads during an accident.

This would result in the HPCS being taken out of senice (February 29 Briefing,page 18). This results in a loss of a vital emergency response system.

18. It is clear that the TDI generators are completely unreliable. The NRC has expressed concern over the multiple and seemingly endless problems with the generators. Harold Denton, the NRC's director of Nuclear }teactor Regulation, has directed that no nuclear plant be allowed to operate with a TDI emergency diesel geni ator until technical questions about their operating history,are answered (see Afdchment 3). Last October, Darrell G. Eisenhut, Director, Division of Licensing,in a letter to NRC Commissioners stated that "the identification of QA problems at TDI, taken together with the number of operational problems and the Shoreharn crankshaft failure, has reduced the staff's level of confidence in the reliability of all TDI diesel generators."

'(See Attachment 4.) Certainly no exception or reduction in scrutiny should be made for G_ rand Gulf, particularly in light of the fact that it is precisely the lack of vigilant regulation and scrutiny that has resulted in a plant with the magnitude of problems present at Grand Gulf being per-mitted to operate at all.

19. The proposals of the Licensee to deal with this, to jury rig gas turbines and to switch the HPCS diesel power over, are makeshift measures to try and compensate for serious deffcien-i cies. This licensee has been unable to conform specifications to physical plant. It is question-able, given the poor management, training data falsification, and discrepancies in specifica-tions and surveillance procedures, whether MP&L really understands the construction and opera-tion of Grand Gulf, Unit 1. If they have not proved competent to even conform to the most basic regulations, they certainly should not be considered competent to implement makeshift measures. For the.NRC to allow this, and once again permit MP&L to proceed in the face of problems and inadequate scrutiny,would be inexcusable.

20. The crankshafts of the TDI generators are inadequately designed. In similar TDI diesel engines at the Shoreham Nuclear Station operated by Long Island Lighting, one crankshaft broke

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and cracks appeared on the remaining crankshafts. Cranksha' problems have also occurred at the Ca.awba plant operated by Duke Power Company. The TD gene aters at Catawba and Grand Gulf ue identical

21. The pistons are inadequately designed. Early on at Grand Gulf, piston crown sepata-tion occuned during operatien. They were returned to TDI for rewerk.TDIis the source of the

,TDI generator malfunctions. There is no indication that any char.ge in design has occurred to ensure that the separation, or other problems, will not recur. Defective performance of the pistons has occurred almost across the board with TDI generators, both at nuclear plants and on marine operation. (See Attachment 1.)

22. The cylinder heads are inadequately designed. At Grand Gulf,three heads'have already had to be replaced due to cracks. Again, cylinder malfunctions have occurred across the board.

with TDI generators. Only redesign, and not replacement, will ensure proper operation!

23. The fuel lines are inadequately designed and/or installed. Numerous fuel line failures have occuped at Grand Gulf 70ne resulted in a major fire. Fuel oillines at Shoreham ruptured.

VIL N. R. C. ENFORCEMENT

~24. The responsibilities of the NRC Office of Inspection and Enforcement (I & E) are i

established by 10 C.F.R.1.64:

The Office of Inspection and Enforcement develops policies and administers programs for: Inspecting licensees to ascertain whether they are complying with NRC regulations, rules orders, and license provisions, and to determine whether these licensees are taking appropriate actions to protect nuclear materials and facilities, the environment, and the health and safety of the public; inspect-ing applicants for licenses, as a basis for recommending issuance or denial of a limited work authorization, construction permit or an operating license; inspect-ing suppliers of safety.related services, components, and equipment to determine whether they have established quality assurance programs that meet NRC criteria; investigating incidents, accidents, allegations, and unusual circumstances includingc those mvolving loss, theft, or diversion of special nuclear material; enforcing Commission orders, regulations, rules, and license provisions; recommending changes in licenses and standards, based on the results of inspections,investiga-tions, and enforcement actions; and notifying licensees regarding generic problems so as to achieve appropriate precautionary or corrective action.... NRC's five Regional Offices are responsible for carrying out inspections and investigations.

25. The lac ~k of decisive actions on the part of I & E, Region II, to ensure that this Licensee meets Appendix A requirements, as well as other regulations, has resulted in conditions that present a serious threat to public health and safety. The staff has allowed the Licensee to get by with prospective commitments, with the result that past defects are not adequately analyzed or corrected. It is inappropriate and totally unacceptable for the NRC to continue to accept the Licensee coming forward with new ' plans"in which it proposes to meet NRC cliteria,

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26. There is no assurance tha: :he public record, upon which the Petitioner must rely,is in any way complete. It is relevant to note that James J. Cummings, director of the Office of Inves:igator and Audi:cr (OIA), responsible for authori:ing a'linves:igations,was removed from his position by the Commissioners in September 1983. The public has no way to know what matters the-NRC and the Licensee have " settled" between themselves, whether properly or improperly.

VIII. RELIEF REQUESTED

27. Petitioner, having shown herein that the Licensee, Mississippi Power and Light Com-pany, has failed to meet the criteria of 10 C.F.R. Section 50 for electric power systems, requests the revocation of the low power license of Grand Gulf Nuclear Station, Unit 1, and a stay of operation, in that prior knowledge of the scope and substance of the Licensee's failure to meet NRC requirements would have caused the Commission to refuse the original application. More-over, the foregoing has demonstrated that the NRC cannot yet make the finding requ!!ed by 10 C.F.Yt. Section 50.57 for issuance of an operating license that there is reasonable assurance that the activities authorized could be conducted without endangering' the public health and safety, and thus the pending application.for full power license should be denied.

28. The request for a revocation of the low power license notwithstanding,the petitioner requests further relief, to inclu'de:

(1) Appointment of an independent panel of investigators from outside the agency to investigate (a) possible improprieties and illegal acts by NRC 3.nspectors rnd investigators;(b) the handling by the OIA of the improprieties which have been previously identified; and (c) the effectiveness of NRC Region II in fulfilling the mandated responsibility to enforce the regulations of the NRC which exist to ensure protection of the public health and safety; (2) Modification of the operating license to include (a) removal from the management organization of those responsible for past failures at Grand Gulf; (b) implementation and verifi-cation of corrective actions for allidentified deviations from requirements; and (3) Hearings before an Atomic Safety and Licensing Board.

IX. CONCLUSION

29. As the foregoing petition has illustrated, the Licensee has not designed, constructed and documented Grand Gulf in compliance with the regiilations of 10 C.F.R. Section 50 and

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-g-in cerfe-ni:y w.th the terrns of its technical specifica:icns and opua:ing license. The evidence presented herein is only that which is in the public record and is but a fraction of the findings tr.ade by the NRC over the ccese of the reguia ory his::ry cf Grand Gulf

50. WHEREFORE, pet::ioner prays for an order g anting the requested relief set forth above.

Respectfu'.ly submitted, i WU Cynthia Stewar:

Jacksonians United for Livable Energy Policies

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en..a.u,,..v r Delaval Diesei Generater Oce-ation Excerience U. S. Nuclear Excerience In 1974, the Long Island Lighting Company (LILCo) contracted with TDI to purchase three emergency diesel generators for the Shoreham Nuclear Power Station.

This was the first order received by TDI to provide an EDG for a cca ercial nuclear power statien.

In the next seven years, engines for 14 other plants were ordered from TDI.

San Onefre 1 Two 'TDI Diesel Encines Installed in 1976 - DSRV-20 Serial No. 75041/52, Rated at 6000KW (nominal) 8800KW(peak)

Engine Run Time to Date - 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> per engine The first plant to actually place a TDI engine into nuclear ;ervice was San

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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

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pumps.

The encines 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 ennnit to neet.the guidelines of Regulatory Guide 1.108, but rather Regulatory Guide 1.9, the progrhm 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 standby.

thrust bearing wear.

Lube oil system modified.

10 CFR Part 21 report isstted because problem generic.

7/81 Lube oil leak and fire.

Excessive vibration of a lube oil test line which had inadvertently been left installed by the licensee.

Line removed.

12/81 Piston modification to Pistons reworked by TDI to prevent crown separation.

respond to Part 21 report.

Problem identified at Grand Gulf.

9/83 Unqualified instrunent R'eplaced in accordance with

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cable.

Part 21 report.

G-ar.d Gulf Two TDI engines installed - Model DSRV-16 Serial No. 74033/34, Rated at 7000XW Operating Heurs to Cate - Division I = 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />; Division II = 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> In 1951, Mississippi Power & Light (MP&L) commenced pre-operational testing of two Y-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 V-16 line of machines for nuclear applications.

The Grand Gulf engines have experienced significant problems in completing the pre-operational test program, have had several major failures, including a fuel line break which caused a fire, and many minor failures.

A detailed list of problems at Grand Gulf follows.

Date Problem Cause/ Solution

• 11/81

. Pisten crown-separation during Holddown studs failed.

operation.

Pistons returned to TDI

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for rework.

Generic problem.

3/81 Excessive turbocharger thrust No lube oil during standby.

bearing wear.

Lube oil system modified.

6/11/82 Air starting valve capstrews 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.

_ au testing.

3/8/82 Air start sensing line not Sensing line relocated and seismically supported, properly supported.

1/29/82 Governor lube oil cooler Lube oil cooler re' located to located too high.

Possibility lower el.evation, of trapping air in system.

3/23/82 Engine pneumatic logic Pneumatic logic design improperly design.

Could co rected.

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result in premature engine shutdown.

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Cate Problem Cause/Sclutien l

4/29/81 Non-Class IE motors supplied Motors replaced with Class 1E l

with EDG auxiliary system qualified motors.

pumps.

3/15/82 Crankcase cover capscrew Capstrews replaced with failed.

Head lodged in higher strength screws.

generator and shorted it out.

Lock tab washers installed.

Generator screens installed.

8/2/83 High pressure fuel injection Manufacturing defect in line failed.

tubin g.-

Tubing replaced.

g/4/83

~ Fuel oil line f. ailed.

Caused High cycle fatigue of major fire.

Swagelock fitting. Additional.

. tubing supports to be installed.

8/11/83 Cracksinc55nectingpush 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 3 tart valve failures.

Cause unknown.

System cleaned and several valves replaced.

More frequent maintenance __

scheduled.

kO/28/83

. Fuel oil leak.

Tubing replaced.

Cracked push rod weld.

Push rod replaced.

'During EDG Cylinder head cracks.

Head replaced.

Installation 12/83 Cylinder 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 instrumeht cable.

Replaced in response to Part 21 report.

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~She eham Three TDI Diesel Engines installed, Model DSR-48 Serial No. 74010-12, Rated at 3500KW Operating hours at tine cf crankshaft failure (8/83)

, G01 = 645 (cracked crankshaf t)

1. 102 = 718 (failed crankshaft) fl03 = 818 (cracked crankshaft)

The engines at Shoreham are the fir:t 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 perfomance of extensive tests in late Septenber 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 & November 3, 1983.

It reported that the crankshaft had been improperly designed, and had failed because the loading function used in the original design calculations was too small.

LILCo also reported that it was investigating four failed cennecting red bearings which were discovered when the EDGs were disassembled. Their preliminary finding was that the failures occurred because the bearing material did not meet specifications, and the bearing loads had not been properly accounted for.

A detailed list of the EDG prcblems at Shoreham follows.

Date Problem Cause/ Solution 3/S1 Excessive turbocharger thrust No lube oil during standby.

bearing wear.

Lube oil system modified.

12/81 Piston modifications to prevent Pistons reworked by TDI to crown separation.

respond to Part 21 report'."

Problem identified at Grand Gulf.

9/82 Engine jacket water pump Water pumps reworked by TDI.

modifications.

6/82 Air starting valve capscrews Response to Part 21 report, replaced.

Too long for holes.

9/82 Engine jacket water pump shaft Pump shafts redesigned and failed by fatigue.

replaced.

Spring /1983 Cracks in engine cylinder heads.

Fabrication flaws.

All heads replaced.

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, Date Preblem Cause/S: ution 3/83

, Two fuel oil injection lines Manufacturing defect in

, ruptured.

tubing. Tubing replaced with shielded design.

3/E3 Engine rocker arm shaft bolt High stress cycle fatigue, failure.

Bolts repicted with new design.

8/12/83 Broken crankshaft.

Cracks in Inadequate design.

Replaced remaining crankshafts.

with larger diameter crankshafts.

9/83 Cracked connecti.ng rod bearings.

.madeque.e design and

• 'sstandard material.

Replaced with new design.,

10/83 Cracked piston skirts.

Replaced all piston skirts with new design.

Generic problem.

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 significant.

9/83 Unqualified instrument cable.

Replaced in response to Part 21 report.

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6-0:e atirc Exterier.ce - hen-Nuclear Marine A:alications Eesides being used for stationary electric power generation, TDI diesel engines have been placed in service as propulsior units en commercial cargo vessels.

As part of the Shereham operating licerse heering, an intervenor, Suffolk County, requested and was granted by the Licensing Board, subpoenas for the State of Alaska, U. S. Steel, and Titan Navigation, Inc. These three organizations cperate vessels which use TDI Y-16 diesel engines which are very similar to most of the TDI units installed in nuclear power plants.

The responses which were received indicate that the TDI engines in marine service for these organizations have experienced severe reliability problems. Most have related to faulty cylinder heads, but they have also included problems with pistons, cylinder liners, turbochargers, cylinder blocks, connecting rods, connecting rod bearings, main journal bearings, and camshafts. A detailed experience list follows. The staff is. reviewing this material to see how much of it is applicable to engines in nuclear serv. ice.

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Marine Experience with TDI Diesel Generaters State cf Alaska, M. V. Columbia

~. _ 'J, Yessel fitted with tw'o DMRV-16-4 Engines - Serial No. 72033/34 Rated at 9200 HP (6900 XW) at 450 RPM

• ~ Vessel and engines placed in service in June 1974.

~*' Each engine has approximately 30,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operating time to date.

Document Date' Preb1'em Description 2

t 12/76

~ All cylinder liner seals replaced.

All cylinder heads have been removed, reinstalled, or renewed at least three t..nes.

All pistons have been removed and

' reinstalled at least once.

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Turbochargers have been removed, repaired and reinstalled, or renewed.16 times due to leaking oil seals, vibration, rotor

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damage, or defective bearing seal housing.

Exhaust manifolds have been removed and reinstalled because of frozen expansion joints and resulting cylinder head flange-face damage.

Lube oil consumption is excessive.

6/15/78 Rapid deteriorations of fire seal rings causing blowby across gasket surface of cylinder heads.

Ye'ry low lube oil filter life (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />).

Caused by blowby of pistons and valve guides.

Stainless steel exhaust bellows burn out rapidly.

Installed backwards by TDI.

11/28/78 (LettertoAlaskafromTDI).

Recommends timing changes to improve turbocharger performance.

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Documer.: Date Prtblem Des cri::icr.

1/31/79 Valve seats and valve guides not concentric.

Results in bad valve contact.

Defective pisten rings shipped as replacement parts.

Reworked cylinder head received from TDI without all requirec modifications and with da7. aged casket face.

Newly furnished cylinder liners received with' incorrect surface finish (twice).

Connecting rod bearings furnished as spare parts were wrong size - 13" vice 12".

Turbocharger. exhaust flex section

-c.

incorrectly furnished by TDI.

2/2/79 Chrome plating failure of piston rings.

Caused heavy scoring of cylinder liner.

Associated cylinder head found cracked.

Seven cylinder heads replaced during 15 weeks of operation.

Excessive -lube oil filter change out rate.

Due to pisten blowby.

Fuel injector spray tips changed at TDI recommendation to reduce carbon buildup and eliminate washing of liner walls 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 trankcases.

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 I,anformatien Memo),

l.

_9 Decument Date pr:blem Descri:ti.

Loose pisten pin end caps.

Incorrect piston crown to skirt bolt tortue.

Bad connecting rod bearings.

Excessive wear, cracks.

Daraged connecting rod bolts.

Valve push rods cracked at weld of ball to pipe.

QC prcblem.

Crankshaft size changed after engines for ship installed.

No notice to owners of reason for change.

Excessive main bearing wear.

-c.

Carshaft lobe hard facing worn.

TDI recommended the installation of a new flexible exhaust duct which was too short (new design).

Installation attempted at insistence of TDI.

Unit damaged by attempt and returned to TDI for repair.

3/19/79 QC or material prcblems with respect to non-concentricity /out-of-rcund valve seats, push rods, rod bolts, bearing shells, valve stem plating.

6/14/79 Thermal growth and cracking of e.haust.

manifold.

12/26/79 Failure of new connecting bearings.

Cracks of 25% of connecting rods.

a

- Deter.ent Date Preble-Cescri: tier.

1/16/80 Ten (10) new cylinder heads have cracks.

This ~ includes 8 that were previously repaired.

Fifteen (15) valves are defective with chroma flaking off the valve stems.

Yalve stems are being defonned.

Five additional push rods have cracks.

Turbocharger air cooler inlet housing is cracked for fourth time.

Internal bracing in engine intercoolers is cracked.

2/5/80 -

Piston rings installed improperly because mistake by TDI in the drawing used by TDI shop.

2/29/80 Piston crown-to-skirt nut torque inconsistent among nuts on various pistons.

Excessive link rod' bushing bail wear caused by improperly relieved, drilled oil passages on'the matching link rod pins.

3/24/80 Abnomal ctrbon deposits and femations poted on pistons and cylinder head assemblies.

..u Fretting of jaw areas of connecting rods.

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Insufficient turbo (manifold) air except at near full speed operation.

Cracked exhaust manifold end plates.

Cracking of connecting rod boxes.

Cracking of newly installed connecting rod bearing shells at 4500/ hours.

Dccu.ent Date Pr:blem Descri:tien Fretting of link rod and link rod pins at their attachment together.

Fretting between link red bushings and link rod bushing bore.

Galling of link rod bushings in way of link rod pin outer drilled oil passages.

Improper wear / contact pattern' on newly installed connecting rod bearings at 4500/ hours.

Four-point loading.

Insufficient connectino rod bearino wear / contact area to journal wherein it is

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less than 15% of the total bearing area..

Upsetting of stems in valve keeper area.

_e.

Damage to number four piston ring and ring groove on all pistons modified during the 1978-79 engine teardown and rebuilt af ter 4500/ hours operation.

Fretting between piston crown and skirts -.

at 4500/ hours since piston modifications.

Variations in piston bolt torque, beyond specified limits, at 4500/ hours since piston modifications.

Damage to rod bolts, including cracking, and damage to threads on both the bolt and in the rod boxes.

4/18/80 Exhaust manifold conversio'n kits received with cuts and grooves in finished surface.

Required rework by owner before installation.

5/12/80 New connecting rods received without required code (American Bureau of Shipping) approval.

TDI did not have record of which rods were shipped with approval or without approval.

Some new connecting rods shipped with oversize bearings but no note to customer informing 'of difference.

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Dccument Date Frcile.r Desc-icticn 5/14/80 Cylinder head returned to TDI has been lost by TDI. Cannot be located.

5/15/50 Cusicmer received new connecting red bolt in rusty concitien with damaged threads.

5/27/80 Customer received reworked cylinder heads with lip left on exhaust seats which prevents valves from seating.

Customer noted that it now was in possession of two cylinder heads with the same' serial number.

Could not install lockwire in new connecting rod cap screw.

Hole drilled partway through with drill broken off in center of hole. Also noted that edges of lockwire holes on other screws had not been rounded to prevent damage to lockwire.

5/29/80 Discovered leaks in newly installed.

exhaust manifold head plates.

9/4/80 (Meeting Surcary)

TDI says that all cylinder head problems should be corrected by new design.

TDI reports that connecting rod bearing cracks could have resulted from bad bearing alloy makeup by vendors.

TDI

.looking at different bearing materials.

TDI stated that they had erred on piston modifications.

Effected others besides COLUM5IA.

9/30/80 Eleven remaining master connecting rods to be sent to TDI to have oversize bearings and cther modifications installed.

Many of the original cylinder heads that were returned to TDI for rework were exchanged for other used heads.'

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Docur.ent Date Preblem Descri tion 11/5/80 Cylincer head changed due to heavy external water leakage.

Severe smoke causing excessive lube oil centaminatien 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 increased torque specified by TDI caused galling.

New connecting rod bearing shell found cracked.

Heavy wear noted on pisten side thrust areas.

Heavy hard carbon buildup noted in

_e.

area of compression 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 exceed 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 machir.ing of engine block.

i 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.

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D::u er.t Date Pr:bler Cescri::ier 3/13/81 Reworked cylincer heads were returned to the customer without removing the grinding compour.d from the valves and valve seats.

Two reworked pister.s returned to customer without roll pins, which lock the securing nuts in place.

Cylinder liner delivered with wrong surface finish.

Cracks found in cylinder blocks.

All replaced.

Main engine blocks found to be cracked and warped.

The. main. block-to-base through bolts appear to have been improperly torqued during initial assembly.

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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 cu-rently do. This was to eliminate cracking of the block near the stud hol es. The customer re-machined each of the 256 head studs to accomplish the same intert.

4/9/81 Several reworked pistons were returned withtu groove pirs.

In resptnse to a request for 2011" capscrews and washers, TDI supplied 1 7/8" capstrews.

Drawings furnished by TDI for head stud modificaticns were not applicable to the studs in question.

50t of the fuel cump bases would not fit onto the new cylinder blocks be'cause of slight changes in the design of the blocks.

D0cument Date Prebler Descri::icn Two new cylinder liners provided with incorrect surface finish.

One new cylinder liner provided with flange thickness larger thar, manufacturer's maximum tolerance.

New connecting red 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 counterbore depths were off to such an extent that difficulty experienced in establishing proper liner c rush.

Weld spatter noted on many seating surfaces. ~

Dirt, sand, and metal showings found in passages and holes which should have been clean.

Cylinder hea'd water port outlet locations varied considerably, causing a water flow 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.

C, racks discovered in the intercooler.

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Oc:u er.: Cate Pr:blem Descr': tier.

7/29/82 "In nine years of cperation every basic encine component has been modified or rehlacedwithanir.proveditem,atleast cice, with the exceptien of the crankshaft (which is cbsclete and has not been used for years), the engine base, the fuel pumps and the governor. The last two items are not manufactured by TDI."

10/15/82 Turbochargers replaced.

Exhaust valve lubricating system to be

-installed.

3/9/E3 Cracks discovered in three cyli.nder heads.

Reworked cylinder returned to customer with tap broken off in threaded hole.

Others returned with internal cracks and damaged flange faces.

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Titan Navigation, M. V. Pride of Texas Vessel fittee with two DMRV-12-4 engines, Serial Nc. unknown F.ated at 7800 HP at 450 RPM Engines installed 1981 - no information on total engine hours to date.

Document Date Preblem Descriotion 7/16/82 Catastrophic piston failure.

Due to crack in piston skirt.

Engine had 5791 hours0.067 days <br />1.609 hours <br />0.00958 weeks <br />0.0022 months <br /> of operation.

4/1/82 Cylinder block broken and cracked.

Cylinder head cracked.

Cylinder liner cracked.

Piston skirt fractured.

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Suspect that all of above problems caused by water leaking into cylinder from air intake manifold.

Leaking tubes found in air intercooler.

8/19/82 Cracks discovered in six piston skirts.

7/22/82 Cracked exhaust valve seats in cylinder -

heads.

Engine had 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> service.

Camshaft lebe design appears to be deficient.

Causes excessive stress on fuel cam lobe and roller.

Tappet assembly rollers severely galled.

Believed to be due to camshaft and lobe ~-

placement and inadequate heat treatment.

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.

Air start valves have suddenly ceased to function, for no apparent reason.

9 a

18 D::urent Date Pr:bler Descrictice Plugs in crankshaft oil ways may be cracking because improper material used.

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Under investigation.

Fuel cil return lines have failed.

To be replaced with heavier wall tubing.

4/1/83 Exhaust valves fail af ter abcut 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> 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 Yessel fitted with two CMRV engines (model unkro r.)

Engine Serial No. 75039-40 No information on engine hours to date.

Decu ent Date Prchlen Descricticn 11/13/80 Cracked cylinder head.

Replaced.

11/.' 7 9 Cracked cylinder head.

Replaced.

6/1/80 Cracked cylinder head.

Replaced.

10/8/81 Cracked cylinder head.

Replaced.

Note:

This information was summarized from "

documents provided by U. S. Steel in response to a' subpoena which asked specifically for information abcut cyliner

. head failures.

Many other portions of the documents were deleted by U. S. Steel, and it appears that the deleted portions referred to problems with other engine parts.

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Other A:riitatiens The staff understands that other TDI engines are in service as stationary electric power cenerators.

The operating history of these engines will be taken ir.to c6nsideratien during the staff assessment of TDI engines.

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Reference List Shoreham Letter dated 1/6/84 from S. McCaffrey (LILCc) te H. Denton (NRC)

Scarc Notification 83-160 dated 10/21/S3 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/S3 from J. Smith (LILCo) to T'. Murley (NRC)

Letter dated. 12/16/83 from I. Dynner (Suffolk County) to A. Earley (LILCo)

Letter dated 10/20/83 from A. Earley (LILCo) to L. Brenner (NRC)

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 Information Notice 83-51, dated S/5/83 IE Inspection Report 99900334/S3-01, dated 10/3/83 15InformationNotice83-58,datedS/30/83 Grand Gulf Letter dated 11/15/83 from L. Dale (MP&L) to H. Denton (NRC)

Letter dated 10/19/83 from L. Dale (MP&L) to H. Denton (NRC)

LER 50-416/83-171/03L-0 dated 11/28/83 Letter dated 10/26/83 fromL. Dale (MP&L)toH.Denton(NRC)

LER 50-416/83-082/01T-0 LER 50-416/83-126/01T-0 O

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Sar. Dr.cfre Unit 1 LER 50-206/81-017 dated S/12/El Letter dated 9'/15/21 fr:m H. Ray (SCE) te R. Engelken (NRC)

LER 4C-206/E0-039 dated 12/23/80 Letter dated 6/8/81 frem J. Haynes (SCE) to R. Engelken (NRC)

Marine A:clications Letter dated 12/21/83 from A. Dynner (Suffolk County) to A. Earley (LILCo)

Includes' many other individual. documents.

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• %s

/A Mssc h n &7 L

_ ' the purpme of the plan to protect spinst sabotage. Ahd "we were even more astounde I < * **

tien rerets of the reactor for 19751979 ard for lHi2 indicating that NRC staff,in fact examined UCLA's a:tW.t:es re!r,ted to physi:a! pr:tection spinst sabotne. - Ahch:e!Kn:pk k:v: intron Fir.'DitM SITES FOR FUTUR E RE ACTORS V.'ikL r;OT BE A pRCSt.EM under mere restrictive pepdation.

density guidelines being censidered by NP.C.acccrd.ng to an Oak P dge Nnient!Idoratory study fer the a;en:3.ne study,wh2ch has nct teen enicJsed by NRC,cenc;ud:: that Nat:e sites ex:st esen in the smes ard semce areas with the largest pcp.datace dens: ties."

In ad6 tion to 48 sites that already have reacters on them.the study identified 90 other sites that meet aD six alternatives for population restrictions considered in the study.The alterr.ative restrictions au started by recuiring no popdation in a circle formed at a half rdle radius and ne more than 250 persons per square r-Le the circle within a tw o.mi!c radas from the site. heycnd twc r.iles.the effe:ts w ere tested using several types cf restrictions.The attematives aUowed e:ther 500 or 750 persons per sqare mde m a cire!e with a 3 mile ra6us and wried from 1,000 to 3,000 gersons per squ.tre r.i! as the max.imum density aUowed within any 22.5 depee sector drawn in the circle with the 30 mile radius.

The study identified five operating plants that would meet ncne of the alternatnes. While the ex.isting reacters would not be affected, new reactors could not be built on the sites if the new restrictions are adopted.

They are In6an Point, Limerick, Mi!! stone, Midland and Zion. Eight other plants met ordy the sector or ra restrictions. Dey a,re Ginna, Fermi, Seabrook, Oyster Creek,Waterford, Braidwood Turkey Point and De study was done as part of an environmentalimpact study that NRCis preparing for possible revision of its siting regulations.The agency issued an advanced notice of p'roposed rulemaking in July 1980, but has suspended consideration of new sitiniregulations untilit makes decisions on source term and severe ac issues. - hmes Br:nscome, W:shington GR AND GULF PROBLEMS MULTIPLY AS LOW POWER LICENSE THREATENED Prospects are dim for quicifissuance of a full power license for Grand Gulf,and one NRC comm is recommending the plant's low power license be suspended. At a hearing on the status of the plant last NRC staff said they couldn't recommend a fuU. power license until problems with the emergency diesel gene alors and with defective technical specifications are resolved. Commissioner Victor Gi!insky said problems at the plant are greater than he thought and he suggested the low power license be suspended untd th sioners are convinced the problems are resolved. Chairman Nunzio Palladino and Commissioner James As

'stine stopped short of recommen6ng the low.powerlicense be suspended but said that before votin power operation they would like a staff update on the areas where the utility did poorly on the last renew.

M:ssissippi Power & Ught (MP&L) officials uid the plant is complete and wiu be ready;for fut pow cperation as soon as the teet specs and tenerator problems are solved,but refused to say wh Gntulf4pjlitane ef 203! ants in the country with Transamerica Delant (TDI) emergency 6esel gen.

erators. Decause of problems discovered in TDI generators at the Shoreham p! ant and elsewhere, NRC newing their use on a case by case basis.MP&L officials uid that ordy two of their three generators that theirs are a 6fferent model than the ones at Shoreham.and that testine shows the generators have a 99 response rate _. In addation,the plant has rented three cat turbtn,es to serve as backups for the TDI gene themselves a backup system. MP&Lis also part of a TDI owners'poup which is working with NRC to ify the generators.

The problems with the tech see.es are more complex. Grand Gulf is the first BWR 6/ Mark !!! reac the country. Recause tech specs weren't anilable.NRC sent MP&L Mark 11 scecs instead as a draft co pectine the utibly to review and adjust them to meet the actual plant description. Although MPA se NPF m'r ~nceeded on the assumption that et had been done and a low power hcense was issued in J l_oF2.The oreblem with the tech specs wasn't discostred until recently. MPilhas asked for 205 changes of which 457e deal with wme t u"her. Of ine fi!3nt M "W-Gibnsky asked how an carber utihty renew of surseillance procedures.which turned up a num deficiencies in the tech specs and the surveillance procedures.dadn't prompt the utihty to look at the entir tech spec packate.J.B. Rachard. Senior vice president for nuclear operations said the review was fo sorveillance procedures, not on the tech specs as a whole. MP&L he said. is working with tvis staf f to co_m isp with a position on the tech spec issue.

Neither staf f not arnhcant renew of t'he specs was adeouste, fluch Thompson of the Office of Nu Reactor Regv!stion admitted. A lung term renew is being conoucted on how the problem occurred to picient it f rom happenmg apirt.he said. In the short term.NRC is requiring utibties to certif that their tech spect are correct.he uti A number " ate strugbng" with the requirement.he uid,but he pects they will comply.For Grand Gulf, NRC has asked the Idsho National Enpneering L 9

settw N stc. - March $.1984

/

s./

i

, /cc On th.:: the fina! tafety F.dys:s rerurt and the safety cElca: un returt ref'iect these correct specs. NRC i

f

/ Eb -

_s::f f c w.::c. ". try:rg to ccitrmme if the s~;a rmich t e r:.:r " 6 "!. Emh ef fmte Q pe-

g J n-2: e n: es. Tncmpsun :::e.'. Aditen:.!iy,

.c' NRC te:' :cl tv6 has been asked to recew

./-

~..-m e - Q rd Cu:f in la'.t er tFe te:h snec dwe be C 1miq w2! je:ned b Asteis'ine and PCdino m mcmg concerr eser the 1: test sys:cmatic assesment t

c.eme re fe m:r:e rii;l rerrt en w r::h Grard Cdf ;c the : owe / ::s: de r:::rg en foe ct.: ef nine c::v :es "r e Se. CJ.msy r c'ed. w c:e the cper::nt opm:icra: c:cior.es (;.ar. cperstions, mamten:nce sa:bce,1.:ensing actmtics and p.cht) assurance).The lowest ratin; s;gnines that the plant is acceptable but needs some attention, the staff poir:ted out. But Asse!stme commented that the staff found the p: ant w rs Fare!y at lowest leselin some of the categories,sometimes dpping esen lower during the year long assess-mer: pened.

NRC s::ff r.:id the renew showed MFil has m:de prepess in sor e of the week areas. J:mes O'ReiHy, Re; cil! adm.n;strator, t. id recent ad6: ens to the nuclear r.anagement suff are substsntialimprc,vements, th:t work has been done on procedures and they are now in "execuent shape,"and that the operator recerti-fia:icn has teen successfuUy comp;eted.

Asseistine,stiU skeptical,sug.gested a speci:1 team be sent to the plant to review each of the categories before the plant comes up for full power operation. "1 think what we're saying is that before we can go for-ward, you have to have a satisfactory rating in each of these categories," Gilinsky added. - FrancerSegherr SEN. ALAN SIMPSON (R WYO,) SAID NRC PROCEDURE ON THREE MILE ISt.AND restart is more of a prob-lem than the question of TMI management integrity. Simpson. chairman of the Senate Environment & Pub-lic Works Subcommittee on Nuclear Regulation, m:de his comments during a hearing on the NRC authoriza.

tion tal for FY-84 and 85. He echoed complaints by Sen. Arlen Specter.(R Pa.) about the length of tirne it h:s taken the commission to deal with the TMI l restart.

"I don't think there's any way yoWeould have constructed this hearing that could have taken any more time than you haur.," Specter said. The issues involved have been considered by five groups, Specter said. He asked why the commissioners hadn't just held a hearing themselves instead. NRC is,:ensidering the integrity of TMI top management, but didn't ask the top two people whether they knew about a!!cged leak rate falsifi.

cation untilIhe years after the TMI 2 accident and a week after he first raised the issue, Specter said. Simpson said NRC is " paralyzed by tentativeness,"and said he would join with S'pecter in proposing legisistion to sim.

plify NRC procedures.

GPU NUCLEAR, NRC STAFF SPLIT ON STATUS OF INTEGRITY ISSUES CPU Nuclear has told NRC that au but Iwo issues, on s list of more than 60 potentialissues otmsnsge-ment integnty have been resolved and should not '.old up Thfee Mile 1s!:nd l 'estan. The NRC staffis mam.

taining that the implications of five major issues remain unknown and should be resolved before TM! l ascends above 257, power, while intervenor Eroups clsim the issues are unresolved and the issues list should be faf longer The confheting elsims were filed with the NRC commis'sioners, who had asked the parties in the restart proceedings to teu them whether the list was accurate and whether each issue had been resolved (INRC,6 Feb.,

5). The list was cornpiled by the commissioners' Offices of General Counsel and Policy Evaluation, and was re-leased after an angry dispute among the commissioners over whether the list should be made public (INRC, 9 Jan.,1).

"Some of the issues included m the proposed list legitimately can be termed 'integnty* issues," GFU Nuclear said. "However, the vast majority of the issues on the proposed hst ofintegrity issues have absolutely no factual re!ationship to the issue of heensee's(CPU Nuclear) integrity.other than mere assertion. In the sb-sence of 3 substantial basis for linkmg each of these issues with licensees' integrity, that issue ought not be treated by the commission as an integrity issue."

Though the commission itself must make the final decisions that " resolve" issues, GPU Nuclear said,21 most all of the issues on the hst base been considered..ind decided in CPU Nuclear's favor, by Atomic Ssfety A Licensing Doards or by NRC inspections or investi;ations. The only exceptions, the utility said, are allega-tiens of falsified leak rates at TMI ! and.2 before the March 1979 accident, which are two of the issues on the hst. The CPU Nuclear fihnt was made before Metropolitan Edison, the General Pubhc Utihties sabsidiary that esn TMI before CPU Nuclesr pleaded guilty and no contest m federal court to criminal counts invniving the 'IMI.2 leak rate tests The issues on the hst mvoke mana;ement knowledge of the alleged falsificshons.

Dut for :ll other issues. CPU Nuclear :id. the commissmn has enungh information to decide them for restart. "Most of the issues on the proposed hst were fully addressed and tesnhed by the licensing bdard on the basis of extensive record endence adduced during the restart proceedmg. A few of the bsted issues were addressed and sufficiently resolved, for purposes of decidme the quesiion of restart,in documents, statements and pleadi.ngs prouded to the commission... Some of the items were unsuccessfully re.ised by the miersenurs

=. _

hr%c.kCrX 3 whenese, t hey reh a mmid be in the heti imeneu'oi ihe camp.my so !o so. I'wn e wa, m mivd wah lat..

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• fer.h > cars. u U:am Catacosmos,a talco decetor sm.e 193,lus been named to sep!nc Pierse. C.nacosmos 4

I w.is chief escentne of 6ect of Apphed Dy: ital Data 'n stems Inc..i lam;. Is'and hwd seminaer company, fmm 19' 9 un:e last Nucmber ed poor te that wat, sus:ani Joesio of the Ibs. Wen LS nut 1.ab.iratory.

I Another ticasure recendy t ken by Ulco le f.dve its Shmchaw related nmtems o in propese a spec:si i

7ns rte:: deve:vp.nent rate" for estabhshed 1.nnt s!md businetics it is hers.? h.o. a. " muse.: by the st :te i

j rate erm:suor, me :n:cante rate wc:.:d result m icgr powc :a;n.

% e;.re; y tt era!! rate it:

escase needed to pay for Shoreitam. Concern oser it.c ant cip:c So1 rate muc se n.a f c ed opmunon to Shm cham.

lhe utihty's proposalis to give its customers wnh yearly demands of 100 Lw or more - about 3000 bu:inesses la dis: curt of about one cent per kilow.,it hour for electri:ny consumed above their 1982 levels.

a:ccrdir; to ancther Lr!co spokesmar.. "Tius is power that wou:dni be used et!.erwise." he s:.:J. "This sheuld j

encourage them to use more power,our reserve powca." Ulco espects no growe m conomipt.on for the next year and.said the spokesman,any increase in power sold would trans!aie into lower rates for everyone.

DENTON BANS OPERATIONS WITH DELAVAL DIESELS UNTIL PROBLEMS RESOLVED Ne nuclear plant will be allowed to operate with a Transamerica Delaval Inc. (TDI)emereenev diesel le9eratqt.nlill.edLni.taLquellions about their egeranne history are.inswered. said liarold Denion NRC's director of Nuclear Reactor Regulation (NRR). His decision rnost immediately puts a hurdle in the paths of the utilities trying to get Shoreham and Grand Gulf.) on line,althout.h there are nine others with TDI diesels.

it was a split crankshaft in one of th;ee TDI diesels at Long Island Ughting Cols (Lilco)Shoreham that first drew attention to them (NW,25 Aug.*83,6). Discovery of more problems with similar diesels at other sites led NRC ofGcials to declare in October 1953 that they would require case.by. case demonstrations of the adequacy of each diesel (Inside NRC,31 Oct. '83,10). Now, sad Denton at a Jan. 26 meeting of his top staff and utility and TDI executives, further inspections at TDl's Oakland. Calif., plant and collection of' more ope. rating data have conviriced NRC staff that the issue is "very serious."Some Ondings have been sent to NRC's'OfGee of Investigations (01). Based on findmgs to date, Darrell Eisenhui, Denton's direcier of li.

censing,said that "out overall confidence in TDI diesel generators had been signincantly reduced," and "their j

reliabibly will have to be demonstrated."

l S:milar problems showed up during testing at Shoreham,Miss:ssi:or Power & Licht's fMP&L)Crand Culf.l.and Southem California Edison's (SCE) San Onofre.1. NDC staffers told the rnecting.They said the same types of problems have occurred m marme,use of the diesels. Cylmder head crackang, piston skirt cracks i

and crown separation, turbocharger vibrations,fuelline failures,and Dres were all experienced in more than one of the diesels,whose operating times varied from 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> at San Onofre.1,which is shut for seismic repairs,to more than 30.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for one in marine use. A review of nine NRC inspections of TDI since l

1979 f. hewed that more than 60 nonconformances and violations had eetn founc Triese muances included missmg ouahty centrol paperwork, mspect ont certi6ed for parts that were not there. and insnections siened off for dates after equipment was actually shipeed.

i Eleven utilities with TDI diesels have formed an owmers' group, hired corsultants,and begun a study l

of both the overall designs and individual components of the TDI diesel madels they own. James McCrue).y, MP&L nuchar vice cresident who is chairing the group,said that Failure Analysis Associates. Stone & Webster and independent consultants have been hired for the effort at the Shorchart sile and al TDl's plant. Ulco's Wdham Muscier said the group plans to produce " document packages"for each of the $7 diesels the group l

owns, de'aihns en;me. specific design and operation studies and preoperatio1al tests. The Grit packages, for the Shoreham and'the Ctand Culf diesels,are due in March. Other utihiies involved in the group and the rlJnis for which they bought TDI diesels are: Culf States Utihties at Rqct liend,Cs.rohna Power & Ught at liarris.l.

Duke Power at Catawba, Cleveland Electric !!!uminanns at Perry, Texas Unknes Semees at Comanche Peak, l

Ceorgia Power at Vogtle, Consumers Power at Midland, Sacramento Municipal Viihty District at Rancho Seco, and SCE si San Onofre l.

At the NRC meetmg, TDI caceutives promised full cooperation wah the owners' gennp.Chnton Mathews.

TDI vice president and general manager,said the company "will apply allour resources to ce,rreet.my prob.

l lems." The cornpany is " dedicated," he said.io quahty.lo supporting the nuclean mdustry and to "dearmg unt henished image." Don ihxby, chairman of the TDI board,said the company welcomed the owners' effort l

hecause "it would be dif0culi,on our ow n,to convmee everyone these itsnes had been properly cared for."

Resolution of the issues is, however,on "the cruical path" for Shoreham and C#and Gulfsi, Denton j

l noted. 'the ihetet generaim issue is the only tlung standmg.hetween Ldco and a law power beense fm Shore.

ham,acconting to an NRC source The Shoreham hunsing board has issued a pain 31imnal deciuno dmnnung sit health and safety issues escept for the TDI gener.oors.he said,nhhng th.o the board will probihty have 3 NtCkl.r)NICN Wl.1%. libenoy 2, i%4 i

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.,..,.4 m ;. E..r P E O. t : - '.: C G " i21:N e.-

j 30t;f t ';0.

ED *15 MEMDRANCL'M FDR:

Chairman palladinc' Cc=nistioner Giiinsky Ccamissioner Rcberts

'on.issi0ner !sselstine Ocmrissioner iernthal

'ccreli G. Eiser.r.ct, L'irectcr i:

Division of Licensing

'5UE'ECT:

NEWINFORMATIDNCONCERIUNGTRA"5AMERICADELAVAL(TDI) EMERGENCY D]ESEL GENERATORS, BGARD !;0T!FICAT10" S3160

- =.

!c accordan'c'e with NRC procedures for ocarc notifications, the following information is being proviced directly to the Commission.

The' appropriate boards and pcrties are being provided with a cc:y cf this memerandum.

The infer.ratier, is r.colicable to Granc Gulf (c'n uncontested case), wnich will be cef:.re the Cem.rission fer full power authorization in November, 1983.

On August 12,192~, during post-modification testing, the main crankshaft en -

ene of the three emergency diesel cenerators (EDG) at the Shoreham Nuclear Tower Station fa'!ed znd orcke inte two pieces.

Tr.e a:ciitant rubsecuer.tly inspected the rer.aining twc ciesel generators" ct Shoreham ar.c icentif tec additienal flaws in the crankshaf ts of these machines in locations similar to Lfe failure of the first machine. A more cetailed description of the failure is contained in Enciesure 1 (IE Informati'on Notice No. 83-58).

The EDGs at Shoreham were manufactured b;. Transanerica'DeLaval !ncorporsted --

(TDI).

TDI has also previdec EDGs to several other nucieer power plants (see Enciosure 1). The only currently operating reactor with iDI diesels is Grand Gulf.

The TDI ciesel at San Onofre is used by Unit 1, which is shutdewn for seismic modifications, and the dieseis at Rancho Seco are not yet installed.

Besides the failure of the crankshaft at Shoreham', the staff has noted the ectur-ence of many minor problems with TDI EDGs, which.are sur.narized in.

The staff would expect minor problems to occur during the startup testing of any large piece of macninery, such as a ciesel generator, but the number of minor prcblems experienced by the TD) machines in nuclear service appears to be abncrmally high (also See Encicsure 4).

G S

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. ' - -ra r- :e t: 7'lete4r 5

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icer i#i+c cen-iticr

.nica imply inat Scrticr.s c# the TD1 ftrlity Assurance f f;} prcgrar. have not

-6e-ca riec ct; ;r t.ccordarte witn the

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..: p ctie r p - e ' # ice :f '.et-igaticns, unicn

.a s rs: ested tha; cein;is r.c-be revesicc to avric cerrrrr' sir.g the in-vestigation.

1s e result of an inspectir,n perferred in.iuly 1983, the staff ice:ntified a actentiti viciation anc several pcter.tial ncncor#crrerce: which are cescribec in IE Inspection Report ;.o. 99900324/E3-01, catec Ocicter 3.

1983 (Ehc1csure 5).

Tr.e 5.crence applicant is investigating the crerksbef t fa.ilure, but does cci

. ' e r. - e publish a reper until la.or ir. Oq eber. The staff has asked the

.......c c -.se: a eer.ict-cf cut;tieri ccrcernir. the ShtretPr 17; CE: 19r, (see. CI'esure f abricatiCn, cperatiCD. and naintenance in its #ailure report tn 3).

A similar list of cuestiers is being developed for other applicants.

The icentificatien cf OA problems at TDI, taken toce'.her with the number of c;eratienti prcble.ns end th~e Shoreham crankshaft failure, has reduced the staff's ievil of confidence in the reliability of all TDI diesel rcr. craters.

The stt #f will recuire, on a case by case basis, a demonstrati'on that these cer.cerns are not applicable to specific diesei generators because cf sub-

!.accert inspections. or testine performed specifically to adcress the, thrve i.atters.

r.:rthcr de.velopments and additionai ir.formt. tion on this sub.iect will be reported to the appropriate Boaros.

k

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c.

._..%.*,G. Eiser Ec', Di rector

>r.

Da'rrel i Division of Licensing

- Encicsures:

(1) lE Information I:ct4r.e F?-58 (2)

Summary of DeLaval DG Problems -

(12/50-8/83)

(3)

Summary cf Se;terber 2, 1983 EDG 11eetine on Shereham (4)

IE 1r.formatien 1ctice E3-51 (5)

IE Inspection Reccrt !!c. 99900334/83-01 With Octcber 3,19E3 Trarsmittal letter to TransA.merica DeLaval, Inc.

e cc:

See next page a

N a

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UNITED STATES OF AMERICA N"CI. EAR REGULATORY CO.51SSION EEFORE T"E CO." MISSION Ir. the Ma'tter cf

)

)

, MISSISSIPPI POWER 6 LIGHT COMPANY, ec al.

)

Docket No.

)

(Grand Gulf Ndc3sar Station, Unit 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the above-entitled "SE0W CAUSE PETITION FROM JACKSONIANS UNITED FOR LIVAELE ENERGY POLICIES' have been served on the fol-loving by deposit in the United States Mail, First Class, this day of April, 1984.

At the U. S. Nucleu Regulatory Commission Robert B. McGehee Washington, DC 20555:

Wise, Carter, Child & Caraway 925 Electric Building Herbert Grossman, Chairman P. O. Box 651 Administrative Judge Jackson,MS 39205 Atomic Safety and Licensing Board Panel Mississippi Power & Light Company Dr. James H. Cupenter ATTN: Mr. J. P. McGaughy, Jr.

Administr.tive Judge Assistant Vice President, Atomic Safety end Licensing Board Panel Nuclear Production P. O. Box 1640 Dr. Peter A. Morris Jackson,MS 39205 Administrative Judge Atomic Safety and Licensing Board Panel Robert M. Rader Conner and Wetterhahn, P.C.

Atomic Safety and Licensing Board Panel fuite 1050 1747 Pennsylvania Avenue, N.W.

Atomic Safety and Licensing Washington, DC 20006 Appeal Board Panel Docketing and Sernce Section Office of the Secretary Individual Co=missioners U.S. Nuclear Regulatory Commission NRC Staff, clo Mary E. Wagner Washington, D.C. 20555 Cynthia Stewart JULEP