Text

Proposed Findings of Fact & Conclusions of Law in Form of Partial Initial Decision Re Emergency Planning & Tdi Diesel Generators.Certificate of Svc Encl
	ML20117L250
Person / Time
Site:	Perry
Issue date:	05/13/1985
From:	Silberg J; CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	;
References
	CON-#285-005, CON-#285-5 OL, NUDOCS 8505160167
	Download: ML20117L250 (162)
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May 13, 1985 UNITED STATES OF AMERICA 00CKETED USMC NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board '

GFFICE OF SECRETAFY In the Matter of ) 00CKlig,. ERVitf.

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-4400L ILLUMINATING COMPANY, ET AL. ) 50-4410L

)

(Perry Nuclear Power Plant, ) .

Units 1 and 2) )

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION (EMERGENCY PLANNING AND TDI DIESEL GENERATORS)

Jay E. Silberg, P.C.

Michael A. Swiger Rose Ann C. Sullivan SHAW, PITTMAN, POTTS & TROWBRIDGE Counsel for Applicants-i

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y TABLE'OF CONTENTS Page OPINION...................................................... 2

. I. HISTORY OF THE CASE................................ 2 II. CONTENTIONS........................................ 7 A. Issue No. 1: Emergency. Planning.................... 7

1. Background and Introduction.............. 7

2. Contention A: State and Local Comments on-ETE Study................... 16

3. Contention J: Incomplete EALs........... 18

4. Contention M: Independent Radiation Monitoring Systems............ 22

5. Contention P: Hospitals................. 29

6. Contention Q: Letters of Agreement for School Buses........................ 39

7. Contention U: Handling Contaminated Property at Reception Centers........... 41

8. Contention Z: Bus Driver Protection..... 43

9. Contention BB: FEMA Interim Report...... 47

10. Contention CC: SER Resolution Items..... 49 B. Issue No. 16: TDI Diesel Generators............... 50

1. Background and Introduction............. 50

'2. Reliability of the TDI Diesel Generators.............................. 56

a. The TDI Diesel Generator Owners Group Program...................... 58

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1. The Sixteen Phase I Components.58

11. The Phase II Design Review /

Quality Revalidation Program....................... 68 '

iii. Engine Teardown and .

Reassembly.................... 69 iv. Engine Maintenance and Surveillance.................. 69

b. Engine Testing..................... 71

3. Summary and Conclusion.................. 72 FINDINGS OF FACT............................................ 73 I. CONTENTIONS....................................... 73 A. Issue No. 1: Emergency Planning................... 73

1. Contention A: State and Local Comments on ETE Study................... 73

2. Contention J: Incomplete EALs........... 76

3. Contention M: Independent Radiation Monitoring Systems...................... 79

4. Contention P: Hospitals................. 86

5. Contention Q: Letters of Agreement for School Buses........................ 96

6. Contention U: Handling Contaminated Property at Reception Centers........... 97

'7. Contention Z: Bus Driver Protection.... 100

-8. Contention BB: FEMA Interim Report..... 103

.9. Contention CC: SER Resolution Items.... 105 B. Issue No. 16: TDI Diesel Cenerators...............lO6

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Page

. CONCLUSIONS OF LAW......................................... 142

--i i ORDER ..................................................... 142

~ Appendix A: Written-Testimony Received into Evidence

- Appendix B:-Exhibits t

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r May 13, 1985 UNITED. STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) -

)

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION (EMERGENCY PLANNING AND TDI DIESEL GENERATORS)

Pursuant to 10 C.F.R. 5 2.754(a)(1), The Cleveland Elec-tric Illuminating Company ("CEI"), acting for itself and as agent for Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company, and The Toledo Edison Company (col-lectively referred to herein as " Applicants"), submits in the form of a partial. initial decision Applicants' proposed find-ings of fact and conclusions of law relating to Issue No. 1 (emergency planning) and Issue No. 16 (TDI diesel generators) in this proceeding. The proposed findings of fact and conclu-sions of law follow-the form prescribed by the Atomic Safety and Licensing Board (the " Board").1/

-]L/ Memorandum and Order (Proposed Findings and Conclusions)

(April'18, 1985).

O f OPINION-

I. HISTORY'OF THE CASE' This-is the second partial initial decision in this con-tested proceeding on the application for operating licenses for 1the Perry Nuclear Power Plant ("PNPP").2/ The application is

~ for 'tte operation of - two boiling water nuclear reactors ,

("BWRs"), Units 1 and 2, at the Perry. site in Lake County, Ohio, located approximately 35 miles northeast of Cleveland on

-Lake Erie.

' Applicants filed.their operating license application for PNPP with'the NRC on June 26, 1980. In February 1981, the NRC published a Federal Register Notice of " Receipt of Application forEFacility Operating Licenses, Consideration of Issuance of Facility Operating Licenses, and Opportunity for Hearing."3/

This notice provided an opportunity for any person whose inter-est might be affected by the proceeding to request a: hearing-and file a petition for leave to intervene. Several intervenor

. groups and individuals filed petitions in response to the Fed-eral Register notice.

. 2/L A somewhat'more extended description of the history of the case is provided here because the Board's first partial initial' .

. decision, LBP-83-77, 18 N.R.C. 1365 (1983), did not set forth a detailed description of the background of this proceeding.

3/ 46 Fed. Reg. 12372 (February 13, 1981).

-- p lBy order ddted April.9, 1981,4/ the Board mdde initial de-terminations concerning' party status and scheduled a special' prehearing conference pursuant to 10 C.F.R. l 2.751a. The Boarduconvened the special prehearing conference in ,

Painesville,-Ohio on June 2-3, 1981,.and thereafter issued a.

Especial prehearing conference order on party status, conten-tions~and discovery.-5/ Party status was granted to Intervenors Ohio Citizens for Responsible Energy.("OCRE"), Tod J. .Kenney,6/

and a number of other in'dividuals and groups consolidated as Sunflower' Alliance, Inc.,.et al. (" Sunflower"). LBP-81-24 at 177.7/. The Lake County Board of. Commissioners and The Lake County Disaster Services Agency'("DSA") were admitted as

.non-party participants pursuant to 10 C.F.R. 5 2.715(c).

LLBP-81-24 at 177.g/ Subsequently,'the Ashtabula County D 4/- Memorandum and Order (Scheduling Prehearing Conference r Regarding Petitions for Intervention),.LBP-81-24, 14 N.R.C. 235

.(1981).

_5/ Special Prehearing Conference' Memorandum and~ Order Con- j cerning Party Status, Motions to Dismiss and to Stay,.the Ad-missibility of Contentions,- and the Adoption of Special Discov-ery: Procedures, LBP-81-24, 14 N.R.C. 175 (1981).

6/ .Mr. Kenney was later dismissed as a party. Memorandum and-Order (Concerning Motion to Dismiss) (April.8, 1982).

7/

s See Memorandum and Order (Concerning The Status of Ashtabula County and Objections to the Special Prehearing Con-

'ference Order, LBP-81-35, 14 N.R.C. 682, 687'(1981) (clarifying Sunflower's consolidated status).

. !/.. 'See LBP-81-35 at 687'(clarifying non-party status of Lake County Commissioners-and Lake County DSA).

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, t Commissioners and Ashtabula County DSA petitioned for and were granted admission as non-party participants under 5 2.715(c).

LBP-81-35 at 688.

The Board in its special prehearing conference order admitted seven issues to the proceeding. LBP-81-24 at 232-33.

In addition, nine late-filed contentions have been admitted in the course of the proceeding. Of the sixteen issues admitted, three have been dismissed pursuant to Commission rule-making or policy statement,9/ and nine have been summarily disposed of as the result of motions by Applicants and the NRC Staff

(" Staff").10/

9/ Those issues were: Issue No. 6.(automatic standby liquid control system): Memorandum and Order (Denying Motion for Sum-mary Disposition on OCRE Issue No. 6 and Dismissing the Conten-tion), LBP-84-40, 20 N.R.C. 1181 (1984); Issue No. 10 (psycho-logical stress): Memorandum and Order (Concerning Psychological Stress Contention), LBP-82-53A, 16 N.R.C. 208 (1982); Issue No.

2 (financial qualifications): Memorandum and Order (Concerning Motion to Dismiss Financial Qualifications Contention) (April 28, 1982).

10/ Those issues were: Issue No. 15 (steam erosion): Memoran-dum and Order (Motions) (March 13, 1985) (" March 13, 1985 Memo-randum and Order") and Memorandum and Order (Motions for Summa-ry Disposition of Issues 1, 15 and 16) (April 9, 1985)

(" April 9, 1985 Memorandum and Order") (providing explanation of earlier order); Issue No. 14 (in-core thermocouples): Memo-randum and Order (Motion for Summary Disposition on In-Core Thermocouples, Issue 14) (February 27, 1985); Issue No. 13 (turbine missiles): Memorandum and Order (Summary Disposition of Turbine Missile Issue), LBP-83-46, 18 N.R.C. 218 (1983);

. Issue No. 9 (polymer degradation): Tr. 827-28 (Prehearing Tele-phone. Conference of May 9, 1983) and Memorandum and Order (Polymer Degradation: Summary Disposition), LBP-83-18, 17 N.R.C. 501 (1983); Issues No. 4 (energency core cooling sys-(Continued Next Page) r Issue No. 3 (quality assurance) was the subject of the first phase of'the evidentiary hearing on May 24-27, 1983 in Painesville. On December 2, 1983, the Board issued a partial initial decision which concluded in favor of Applicants. Par-tial Initial Decision (Quality Assurance Contention),

- LBP-83-77, 18 N.R.C. 1365 (1983). That partial initial deci-sion was affirmed by the Appeal Board.11/

. The second phase of the hearing, which is the subject of this partial initial decision, concerned Issues No. 1 (emergen-cy planning) and No. 16 (TDI diesel generators). Direct testi-mony was filed on March 25, 1985. The hearing was held on April 9-12, 1985 in Perry, Ohio. The Board received limited appearances pursuant to 10 C.F.R. $ 2.715(a) during an evening session on April 11, 1985.12/

(Continued) tem), No. 11 (environmental impact statement cost-benefit bal-ance) and No. 12 (economic costs of serious accidents): Memo-randum and Order (Concerning Summary Disposition), LBP-82-119, 16 N.R.C. 2063 (1982); Issues No. 5 (scram discharge volume piping) and No. 7 (Asiatic clams): Memorandum and Order (Con-cerning Summary Disposition: Quality Assurance, Corbicula and Scram Discharge Volume Contentions), LBP-82-114, 16 N.R.C. 1909 (1982).

11/ ALAB-802, 21 N.R.C. (March 26, 1985).

12/ The Board also granted an unscheduled limited appearance on April 12, 1985. Tr. 2907-11.

m

The third phase of the evidentiary hearing, which was held on April 30 through May 3, 1985, addressed Issue No. 8 (hydro-gen control)~ and will be the subject of a subsequent partial initial decision.

4 The decisional record of the proceeding for the second phase consists of the testimony and exhibits filed by the par-ties, and the other evidence contained in the transcripts of the hearing.13/ In preparing our decision, we reviewed and considered the entire record and the proposed findings of fact and conclusions of law submitted by the parties. Those pro-posed findings and conclusions that are not incorporated di-rectl'y or by inference in this partial initial decision are re-jected as.being unsupported by the record of the case or as being unnecessary to the rendering of this decision.

This Board's jurisdiction is limited to a determination of findings of fact and conclusions of law on matters put into controversy by the parties to the proceeding or found by the Board to involve a serious safety, environmental, or common de-fense and security question.14/ The Board has made no such IJ/ Appendix A to this partial initial decision identifies, by witness, the location of written testimony in the transcript.

Appendix B lists the exhibits identified, indicates the Board's ruling on any offer of an exhibit into evidence, and identifies the location of admitted exhibits in the transcript.

14/ '10 C.F.R. $ 2.760a. See Houston Lighting and Power Co.

(South Texas Project, Units 1 and 2), LBP-81-54, 14 N.R.C. 918, 922-23 & n.4 (1981).

p.

additional determinations-in this case.

I I '. CONTENTIONS A. Issue No. 1: Emergency Planning

1. Background and Introduction

.In the special prehearing conference order, the Board admitted a broad emergency planning contention, Issue No. 1,

- which stated:

Applicants' emergency evacuation plans do not demonstrate that they provide reason-able assurance that adequate protective measures can and will be taken in the event of an emergency.

LBP-81-24 at 189, as modified by LBP-81-35 at 686.15/ The Board in admitting this broad contention noted that " state and local emergency plans . . .-have not yet been completed . . ."

for the plume exposure pathway-Emergency Planning Zone ("EPZ")

for PNPP. LBP-81-24 at 189.

After well-develcped offsite plans had been available for some time, and following extensive discovery, Applicants (with the support of the Stiff) moved for a Board order requiring

15/ The Board subsequently noted that the words " State and local" should be substituted for the word " Applicants'" in the wording of the contention. Memorandum and Order (Particulari-zation of Emergency Planning Contention), LBP-84-28, 20 N.R.C.

129,.130 n.1 (1984).

L

particularization of the broad contention. The Board granted Applicants' motion, directing Intervenor Sunflower 1g/ to "specify in a written filing the specific inadequacies alleged to exist in the draft local and State emergency plans . . . ."

LBP-84-28, 20 N.R.C. at 132.

Sunflower responded to the Board's order by filing a num-ber of what it termed " particularized objections" to the State, County and onsite emergency plans. Based on Sunflower's fil-ing, Applicants,'with the support of the Staff, moved to dis-miss Issue No. 1 from the proceeding. The Board denied Appli-cants' motion, and reworded and admitted as contentions 18 of Sunflower's " objections."12/ Summary disposition motions on all of the-admitted contentions subsequently were filed by

. Applicants (and supported by the Staff), and were granted with respect to nine of the contentions as well as parts of two others.lg/

Ig/ Sunflower was designated lead intervenor on the emergency planning issue in the Board's Memorandum and Order (Concerning Redesignation of Lead Intervenor) (October 13, 1981).

12/ Memorandum and Order (Admissibility of Contentions on Emergency Plans and Motion to Dismiss) (January 10, 1985)

(" January 10, 1985 Memorandum and Order"). The Board expressly rejected all allegations of the proposed contentions not in-cluded in the contentions as framed by the Board. Id. at 5.

13/ March 13, 1985 Memorandum and Order. See April 9, 1985 Memorandum and Order.

Summary disposition of the following contentions was (Continued Next Page)

. :o

-The following seven contentions and parts of two conten-tions on emergency planning remained at issue for the hearing:

Contention A: State and local comments on Evacuation Time Estimate study Contention J: Incomplete Emergency Action Levels Contention M: Independent radiation monitoring systems Contention P: Hospitals Contention Q: Letters of agreement for school buses Contention U: Handling contaminated property at reception centers Contention Z: Bus driver protection f Contention BB: FEMA Interim Report Contention CC: SER resolution items (Continued) granted in full: Contention B (evacuation route impediments; evacuation of onsite construction workers; consideration of low or no power operation during extreme inclement weather); Con-tention'C (legal authority and role of County Commissioners);

Contention G (availability of potassium iodide for emergency workers and the public); Contention H (radiation exposure lim-its and respirators for emergency workers); Contention I (evac-uation beyond 5 miles); Contention O (reentry and recovery of property); Contention DD (location of the Emergency Operations Facility); Contention GG (communication with people who do not use radios or televisions); Contention JJ (availability of back-up power.for evacuation).

Those contentions on which summary disposition was granted in'part are discussed infra.

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o

~The texts of-these contentions are provided in the discussions of' individual contentions, infra.

The evidentiary record for the emergency planning conten-

-tions includes the written and/or oral, testimony of eight wit-nesses for Applicants, one witness for the Staff, one witness

'for the Federal Emergency Management A'gency (" FEMA"), and two witnesses for Sunflower.

Addressing the contentions (A,-J'and CC) relating to the adequacy of the PNPP onsite plan ("PNPP Plan") on' behalf of the Staff was Mr. Donald J. Perrotti. As an Emergency Preparedness Specialist in the Emergency Preparedness Branch, Division of

' Emergency Preparedness and Engineering Response, Office of Inspection and; Enforcement of the NRC, Mr. Perrotti is respon-sible.for review and evaluation of radiological emergency re-sponse plans, including the PNPP Plan, submitted by reactor applicants and licensees. Testimony of Donald J. Perrotti Regarding Emergency Plan Issues, ff. Tr. 3111 (hereinafter "Perrotti"), at 1, Attachment at 1.

Addressing the contentions ( A, M, P, Q, U, Z and BB) relating to the adequacy-of the State and County emergency

. plans on behalf of FEMA was Mr. Robert'O. Shapiro. Mr. Shapiro-is an Emergency Management Specialist in the Technological Haz-ards Branch, Natural and Technological Hazards Division of FEMA, Region V. He is responsible for the review and evaluation of State and County radiological emergency response plans, including the plans of the State of Ohio and the three counties - Lake, Ashtabula and Geauga - which are partially within the PNPP plume exposure pathway EPZ. Testimony of Robert O. Shapiro, Federal Emergency Management Agency Regard-ing Emergency Planning Contentions A, M, P, Q, U, Z, BB, ff.

Tr. 3111 (hereinafter "Shapiro"), at 1-2, Attachment at 1.

Addressing the nine emergency planning contentions for Applicants was a series of witnesses. Those witnesses are identified infra in the discussion of specific contentions.

Sunflower's witnesses were Dr. Ernest J. Sternglass and Dr. Robert L. McTrusty. Dr. McTrusty, whose pre-filed written testimony addressed Contention P, is an obstetrician /

gynecologist, and was identified as chairman of the Ashtabula County Medical Center Disaster Committee. Testimony of Dr.

Robert L. McTrusty, Chairman, Ashtabula County Medical Center Disaster Committee, ff. Tr. 3149 (hereinafter "McTrusty"), at

1. Dr. McTrusty was unable to appear at the hearing due to scheduling difficulties, and his written testimony was received into evidence without cross-examination by stipulation of the parties. See Tr. 3148-49.

Dr. Sternglass' testimony addressed Contentions J, M, P and Z. Dr. Sternglass is Professor Emeritus of Radiological Physics, University of Pittsburgh School of Medicine, F

.. -o Department of_ Radiology. Testimony by-Dr. Ernest J.

Sternglass, ff. Tr. 2566 (hereinafter "Sternglass"),19/ at 1.

Dr. Sternglass has testified over the years before numerous legislative, administrative and other bodies on the health ef-fects of low levels of radiation. Sternglass"at 2; Tr. 2596

'(Sternglass). Applicants' counsel cross-examined Dr.

Sternglass at length concerning the findings of various groups with respect to Dr. Sternglass' views, including the National Academy of Science Advisory Committee on the Biological-Effects-of Ionizing Radiations,-the United States Environmental Protec-tion Agency, the Committee on Environmental Hazards of the American Academy of Pediatrics, the Health Physics Society, and the NRC. See Tr. 2596-2645 (Sternglass).

It appears from the record that Dr. Sternglass' theories on radiation health effects have been rejected by virtually every scientific group and governmental body to which he has presented them. More importantly for our purposes, the consen-sus of the scientific community seems to be that >

Dr. Sternglass' work is fundamentally characterized by the se-lective and biased use of data. See, e.g., App. Ex. 1-1, ff.

Tr. 2602, at 178;20/ App. Ex. 1-4, ff. Tr. 2618, at 2;21/

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19/ The Board ordered the words " Summary of," which appear in the original, stricken from the title of Dr. Sternglass' testi-mony. Tr. 2564.

20/ "It is clear that the correlations presented in support of the hypothesis depend on arbitrary selection of data supporting (Continued Next Page) r n

t

- App. Ex. 1-5, ff. Tr. 2620;22/ App. Ex. 1-6,.ff. Tr. 2622;2y ..

App. Ex. 1-8,-ff. Tr.

' App. Ex. 1-7, ff. Tr. 2625, at 1;24/

2627, at 2-3.25/

(Continued) the h'ypothesis.and the ignoring o'f those that do.not. In sev-eral regards, the data used by Sternglass appear to be in 7 error." Report of the Advisory Committee on the Biological Efd I ^v facts of Ionizing Radiations, National Academy of Sciences (1972).

~

21/ . . . Dr. Sternglass has brought together a series of _

data interpretations which seem plausible on casual review, even to technical people. However, on closer look it becomes '

readily apparent.that this report has many misinterpretations *

- which tax even the experts to clarify." Letter to Christopher J.'Dodd, House of. Representatives, from Douglas M.

Costle, Administrator, U.S. EPA (August 9, 1978). ,

.m

j j!b/ '"Dr . Sternglass has been presenting similar reports for -

the last 10-years which, on careful analyses, have been.shown by a number of reputable scientists tojbe based-on a-highly se-lective and.very' biased use of mortality data. In'every case we have found that Dr. Sternglass only uses data which support his pronounced views which are usually directed againstvnuclear power." Letter to' James C. Cleveland, House of ,Representa-tives, from W.D. Rowe, Deputy Assistant Administrator of Radia-

- tion Programs, U.S. EPA (August 2, 1978).

. 23/ ". . . Dr. Sternglass tends to select that data he uses and does not subject his statements to peer review.," Letter.to Bo Lindell,~ National Institute'of Radiation Protection, '

Stockholm, from William A. Wills, Director, Criteria & Stah-dards Division, Office of Radiation Programs, U.S. EPA- s'.

(February 7, 1980).

24/- "He has selected data to prepare his hypothesis without considering the far more extensive data that do not support

- it." Committee Statement of Committee on Environmental Haz-ards, American Academy of Pediatrics (1970).

15/ f"At.the core of the phenomenon appears to be Dr. Sternglass' careful selection of only that data he finds will support the conclusions he wishes to reach. Toward that (Continued Next Page)

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The-Appeal Board has concluded the following about Dr.

Sternglass:

. . . Dr. Sternglass' statistical methodol-ogy and selective sampling techniques are not scientifically credible and indeed raise serious questions as to whether his presentation is consistent with even a mod-erate degree of scientific responsibility.

Trustees of Columbia University in the City of New York, ALAB-50, 4.A.E.C. 849, 862 (1972), aff'd sub nom. Morningside a

Renewal Council, Inc. v. A.E.C., 842 F. 2d 234 (2d Cir. 1973),

cert. denied, 417 U.S. 951 (1974). The United States Court of Appeals of the Third Circuit also has criticized "the question-able nature of many of the. assumptions relied upon by Dr. Sternglass and the resulting imprecision of his

_. calculations . . . Punnett v. Carter, 621 F.2d 578, 586 (1980). See id. at-583-86. Dr. Sternglass' methodology and conclusions similarly have been rejected in Tennessee Valley Authority (Hartsville Nuclear Plant, Units lA, 2A, 1B, and 2B),

(Continued) end he apparently has no qualms in changing facts such as which way the wind blows and making water flow upstream; or corrobo-

~ rating as supporting references his own previous papers; or ignoring the protests of other scientists whose research he sometimes cites; or displaying no apparent interest in the mass

- of scientific opinion which rejects his methods of research and x findings as bunk and pseudo-science; and when being questioned,

' invariably changing the subject or always displaying 'new 9- data.'" ' Statement of Dade W. Moeller, President, Health Phys-ics Society-(1971).

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.ALAB-463, 7 N.R.C. 341, 349-51 (1978);- Long Island Lighting Co. ,

(Shoreham Nuclear Power Station, Unit 1), ALAB-156, 6 A.E.C. 831, 850 (1973);fDuquesne Light Co. (Beaver Valley Power Sta-tion, Unit No. 2),'LBP-74-25, 7 A.E.C. 711, 719-20 (1974);

' Toledo Edison Co. (Davis-Besse Nuclear Power Station), 3 Atomic Energy Law Reporter (CCH) 17735-30, 17735-38 to -43 (1973);

Consumers Power Company (Midland Plant, Units 1 and 2),

.LBP-72-34, 5 A.E.C. 214, 226 (1972), aff'd in relevant part, ALAB-123,'6-A.E.C. 331, 344-45 (1973); Toledo Edison Company

.(Davis-Besse Nuclear Power Station), 4 A.E.C. 571, 584-85 (1971)). See Carolina Power & Light Co. (Shearon Harris Nuclear Plant, Units.1 and 2), LBP-84-15, 19 N.R.C. 837, 838-39, 843-44 (1984); LBP-84-7, 19 N.R.C. 432, 438 (1984).

.Dr. Sternglass' response to what he acknowledges to be widespread rejection of his views is that there is a deliberate l 1

" coverup" or'" conspiracy" on the part of governmental agencies !

and established scientific groups to suppress information which supports those views. See, e.g., Tr. 2613-15, 2634-35, 2654.

~We agree that'"[sjuch a vast ' conspiracy' at all levels of gov-ernment and in industry and science is too big to swallow by any reasonable person." App. Ex. 1-8 (Statement of Dade W.

Moeller, President, Health Physics Society, at 6.

The Board, based on its consideration of this body of criticism, concludes that Dr. Sternglass' credibility has been

. o seriously impeached. Consequently, the Board believes that the testimony of Dr. Sternglass should be accorded no weight in i

deciding the contentions addressed by his testimony. '

2. Contention A: State and Local Comments on ETE Study The portion of Contention A which was not summarily dis-posed of concerns the issue of obtaining comments from state and local officials on evacuation time estimates. See Finding 1.

Applicants' witness on Contention A was Mr. Scott T.

McCandless of HMM Associates, Inc. Mr. McCandless was Principal-in-Charge of the evacuation time estimate study pre-pared by HMM for the PNPP plume exposure pathway EPZ. That study is entitled " Evacuation Time Estimates For Areas Near The Perry Nuclear Power Plant" (the "ETE"). Applicants' Direct Testimony of Scott T. McCandless on Issue No. 1 - Contention A, ff. Tr. 2791 (hereinafter "McCandless"), at 1. Mr. McCandless has supervised or otherwise participated in evacuation time es-timates for numerous other nuclear power plants as well, and has extensive experience in the general areas of emergency planning and transportation planning. Statement of Qualifica-tions of Scott T. McCandless, ff. Tr. 2790; Tr. 2793-94 l

(McCandless).

I L

Appendix 4 to NUREG-0654/ FEMA-REP-1, " Criteria For Prepa-ration and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Rev. 1, November 1980), sets forth the regulatory acceptance criteria

~

for evacuation time estimate studies. Appendix 4 provides, in relevant part, that review of the draft ETE by the principal organizations (State and local) involved in emergency response for the site shall be solicited and comments resulting from such review included with the submittal of the ETE. Finding 2.

The testimony presented by the witnesses for Applicants, FEMA and the Staff 26/ clearly established that the ETE has been reviewed by the State of Ohio and the three counties,27/ and that the resulting comments were included with the submittal ^of the February 1985 revision of the ETE to the NRC. Findings '

3-7. Each of the principal response organizations has subse-quently expressed-concurrence with the changes made to the ETE as a result of its comments. Finding 7.

The Board agrees with the Staff's and FEMA's conclusion that Applicants have complied with the regulatory guidance ap-plicable to this contention. See Finding 8. Nothing in 26/ Sunflower submitted no direct testimony on Contention A.

27/ Indeed, offsite emergency planning / response officials have played an important role in.the development of the PNPP ETE.

Thus, the participation of these officials has gone far beyond a mere " review" of the ETE. Finding 3.

6-s r -

Sunflower's cross-examination of Applicants', FEMA's or the Staff's witnesses provides a basis for questioning that conclu-sion.

3. Contention J: Incomplete EALs This contention was based on the incomplete status of.sev-eral Emergency Action Levels ("EALs") in Table 4-1 of Revision 3 of the PNPP Plan, dated April 23, 1984. EALs describe spe-cific plant conditions at which one of -the four Emergency Clas-sifications (Unusual Event, Alert, Site Area Emergency, General Emergency) are to be declared. Finding 10.

Applicants' witness on Contention J was Mr. Daniel D.

Hulbert, Emergency Planning Coordinator, Perry Plant Technical Department, CEI. Mr. Hulbert is responsible for developing, maintaining, and evaluating the PNPP Plan. His responsibilities include.the development of EAL indications. Applicants' Direct Testimony of Daniel D. Hulbert on Issue No. 1 - Contention J, ff. Tr. 2965 (hereinafter "Hulbert (Contention J)"), at 1.

Of the over 200 individual EAL indications in Revision 3 of the PNPP Plan, only 13 were incomplete. In each case, the value to be included later was not available at the time Revi-sion 3 was issued, because the value could only be determined after the detailed technical data became available. However, in every case a comparable value was specified. Findings 11-12.

1 m ., _ _ ~_

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For each of these 13, either the " missing" values have now

.been~ developed based upon additional detailed information which became available after Revision.3 was issued, or alternate in-dications have been selected. In all cases, these have been

includedLin Revision 4.to the PNPP Plan, which was issued in' February 1985. Finding 13.

Nevertheless, Sunflower's witness, Dr. Sternglass, - main-tained that the 13 EALs still are " incomplete."- First, ac-

cording to Dr. Sternglass, Applicants have not provided a suf-4 ficiently detailed technical basis for the evaluation of the EALs which now have been supplied. Sternglass at 3-4. Yet Sunflower's counsel failed to cross-examine Mr. Hulbert con-cerning the detailed technical basis for the 13 EALs. See Tr.

2966-76-(Hulbert). Moreover, Mr. Perrotti testified that the Staff's review to date.of Applicants' emergency classification and-action level scheme shows that Applicants' emergency plan

,- is adequate in this regard. Finding 14.

4-I.

Dr. Sternglass' argued, second, that the EALs are "incom-plete" because " existing regulations" require that nomograms 28/

. be developed which address a range of possible EALs, and be-cause such nomograms are not included in the PNPP Plan.

'Sternglass at 4-5. See Finding 15.

~

28/. Dr. Sternglass' testimony actually read " monograms" in-stead of " nomograms." Sternglass at 4. Dr. Sternglass ap-peared confused about the difference between a monogram and a nomogram. Tr. 2647-48 (Sternglass).

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. o In fact, nomograms are not required by any regulation, but were merely recommended in an EPA Manual. The EPA Manual went on to say that other " shortcut" dose projection methods may have been developed that are just as accurate as nomograms; and these methods should be used if appropriate. Finding 15.

Nomograms have become obsolete since the EPA Manual was writ-ten. Nomograms are not a useful tool because they require a number of assumptions, are good for only a limited number of cases, and are -typically difficult -to read and -interpret. The current method of dose projection, which.is used by Applicants, is a computer-based system which uses real time data from in-plant monitors and meteorological data for rapid dose as-sessment calculations. This method is-far superior to nomograms for use during an emergency. Finding 16. The Board finds, based on the testimony, that there is no regulatory requirement to use nomograms, and that Applicants' dose projec-tion method is an adequate and preferable alternative.

Third and finally, Dr. Sternglass asserted that Appli-cants' information on the EALs is " incomplete" because Appli-cants' emergency plan contains a wrong assumption concerning the sensitivity of the fetus to radioactive iodine. Specifi-cally, Dr. Sternglass objected to Footnote 3 of Table 6-2 of the PNPP Plan, entitled " Guidelines for Protection Against In-gestion of Contamination," which indicates that the sensitivity of the newborn infant is considered to bound that of the fetus i

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with respect.to the-effectslof ingestion of Iodine-131.

Sternglass at 5; Tr. 2651 (Sternglass). Footnote 3 of Table 6-2 is taken from federal Food and Drug Administration recom-mendations for ingestion pathway protective action guides

("PAGs"). Finding 17.

There is no connection between protective action guides for the ingestion pathway and EALs, nor was Dr. Sternglass able

= 'to show such a relationship. Finding 18. See Tr. 2650 (Sternglass). Because the Board finds that no relationship was

- established between Table 6-2 of the PNPP Plan and the EALs, it is not necessary to reach Dr. Sternglass' arguments concerning possible differences between fetal and newborn sensitivity to radiciodine. Licensing Boards are restricted to adjudicating only those matters raised by the contentions. See supra p. 6 and note 14. -In view of Dr. Sternglass' lack of credibility, as discussed supra, the Board in any event would not have found-those arguments persuasive.29/

In conclusion, the Board finds that Applicants' EALs in 4 Table 4-1 of the PNPP Plan are complete. Further, no evidence was adduced by Sunflower which could provide a basis for questioning the adequacy of the 13 previously incomplete EALs.

29/ See Duquesne Light Co. (Beaver Valley Power Station, Unit No. 2), supra,.7 A.E.C. at 718-20, 742. The licensing board in Beaver Valley concluded, contrary to testimony by Dr.

Sternglass, that " young children represent the most critical

- portion of the population with respect to environmental expo-sure from radiciodine and not the infant in utero."

,,y-- - -

4. . Contention M: Independent Radiation Monitoring Systems-Contention M states-that Independent Radiation Data Moni-toring Systems should be installed within the PNPP plume expo-sure pathway EPZ. Sunflower's argument is that each of the

'three counties within the plume exposure pathway EPZ should have fixed' radiation monitors, meteorological equipment and telemetering equipment.

Applicants presented two witnesses on this contention ,

Mr. Richard R. Bowers'and Mr. Kenneth B. Cole. Mr. Bowers is CEI's Corporate Health Physicist, with 30 years of health phys-ics experience. He has technical overview responsibilities for both CEI's operational health physics program and engineering health physics program. Applicants' Direct Testimony of Richard R. Bowers on Issue No. 1 - Contention M, ff. Tr. 2914 (hereinafter " Bowers"), at 1; Tr. 2915-(Bowers). See Statement of Qualifications of Richard R. Bowers, ff. Tr. 2913. Mr. Bow-ers also has been a technical advisor for some time to Lake County regarding the County's development of an independent monitoring capability. Tr. 2932-33, 2956-57 (Bowers).

Mr.. Cole is Nuclear Operations Officer for the ODSA. He supervises the three sections of ODSA which deal with radiological matters for the State of Ohio. Those matters in-clude, among other-things, response to accidents involving radiological materials, and training of emergency response a

l workers to conduct radiological monitoring. Professional Qual-ifications of Kenneth B. Cole, ff. Tr. 2834, at 1.

There is no regulatory requirement or guidance that each jurisdiction within the plume exposure pathway EPZ have inde-pendent radiation monitoring systems. NUREG-0654 states that each emergency planning organization shall-describe the moni-toring capability on which it will rely. Finding 20. The State and County plans for the PNPP plume exposure pathway EPZ meet this criterion. Finding 31.

Nor is there any regulatory requirement or guidance which states that'any independent off-site monitoring which may be provided must be a fixed system. Finding 21. Mobile-moni-toring teams in fact provide the most effective, as well as ef-ficient, method to track and measure offsite doses. Finding

22. The principal advantage of mobile teams is that mobile teams,.unlike stationary monitors, are able to locate and take measurements at the centerline of the radioactive plume, which is necessary for meaningful dose measurements and ex-trapolations. A dose measurement at a particular fixed-monitor

.cannot be extrapolated to project the doses at other locations, because there is no way to know whether the monitor happens to be located at the centerline of the plume. Although a fixed monitoring system would give instantaneous readouts, the data would be of questionable value. For this reason, even a fixed monitoring system in combination with mobile monit'oring would not~have any advantage over mobile monitoring. Finding 23.

In addition, mobile monitoring teams are more cost-effective than stationary monitoring systems. FEMA recom-mends mobile monitoring teams and rejects stationary systems for this reason. Finding 24. The cost for installation and operation of a stationary system for PNPP would be substantial.

Approximately 100 fixed monitoring locations would be needed.

Finding 25. A fixed monitoring system would not replace either the CEI or State monitoring teams, the PNPP in-plant effluent

-monitors, or the State, CEI or NRC thermoluminescent dosimeters. Finding 26. Although Sunflower's witness, Dr.

Sternglass, argued that the cost of a fixed monit.oring system would constitute only a small fraction of the total cost of the plant (Sternglass at 9), the Board finds this comparison inap-propriate. Almost any expenditure could be justified by comparing it to the total cost of the plant.

There will be multiple, independent radiation monitoring systems operating within the PNPP plume exposure pathway EPZ in the event of an accident at the Plant. The State of Ohio will field three fully trained and equipped mobile survey teams in the event of a radiological emergency at PNPP to provide inde-pendent monitoring assessments. Finding 27.30/ Team members 30/ In addition, the local ODSA representative for Lake County has-the ability to conduct field monitoring if necessary.

Finding 27.

r

' .1 .. -

are identified-and placed on " alert" at an Unusual Event, and are dispatched at the Alert emergency stage. The response team supervisor is dispatched by helicopter to the site area to per-form-an aerial survey. The helicopter's response time to the

-PNPP site-is about.one hour and 15 minutes, and the field teams are in place 3'to 3 1/2 hours after they are dispatched. Find-ing'28.

The_ State monitoring. teams obtain radiation readings for the State's Dose Assessment Group in the State Emergency Opera-tions Center ("EOC") in Columbus. The information received from the monitoring teams is fed into a dedicated computer sys-tem in the State EOC which plots the plume and identifies plume

-parameters. Field , monitoring teams are directed by the-re-sponse team supervisor operating out of the State communica-tions van. The supervisor is in direct communication with the State EOC, the County EOCs, the PNPP' Emergency Operations Facility (" EOF"), and the State monitoring teams. Findings 29-30.

The State of Ohio's field monitoring teams have demon-strated their ability to perform accident assessment during eight emergency planning exercises, including the November 1984

. exercise-for PNPP. All three counties within the PNPP plume exposure pathway EPZ rely on the State's field monitoring capa-bilities. Finding 31.

Independent monitoring assessment also will be provided by Lake County, which will maintain two fully trained and equipped monitoring teams for response to a radiation emergency at PNPP.

Each team will consist of two Lake County Health District employees who will be trained to perform both radiation and airborne activity surveys. For each team, two additional trained personnel will be available as backups. Finding 32.

The Lake County monitoring teams will be activated at the Alert emergency stage. It is estimated that the teams can be dispatched and in place within 1.0 to 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months during normal working hours, and within 1.5 and 2.0 hours0 days 0 hours 0 weeks 0 months during off-work hours, after declaration of an Alert. The teams will communi-cate with the County EOC, and will perform surveys as directed by the Ccunty Radiological Officer in the EOC. Finding 33.

In addition to the State and Lake County, the Department of Energy, the U.S. EPA, and the NRC all have radiation field monitoring capability in the event of an accident at PNPP. A central location for consolidating and coordinating all field data - the Federal Radiological Monitoring and Assessment Cen-ter - would be set up by DOE and would relay information to the State and County EOCs, the EOF and FEMA. Finding 34.

The PNPP Plan calls for two CEI radiation monitoring teams

-to be dispatched at an Alert, and a third team to be dispatched at a Site Area Emergency, to monitor the actual conditions downwind of the plant. Additional teams may be organized as the situation warrants. Finding 35.

The CEI teams will provide field monitoring capabilities prior to the deployment of the State and County teams. Depend-ing.on the time of day and site staffing, teams can be dis-patched and in place within 30 to 45 minutes after declaration of an Alert. Finding 36.

Dr. Sternglass argued that a report on the Three Mile Is-land accident demonstrates the drawbacks of relying on mobile monitoring methods such as car-mounted or helicopter-mounted instruments. Sternglass at 7-8. However, Dr. Sternglass was l

unable to show that the TMI report addresses car-mounted equip-ment. See Tr. 2667-69, 2709 (Sternglass). He also failed to show-that the TMI report documents cases of missed releases or inaccurate measurements when helicopters were actually flying.

See Tr. 2669-71 (Sternglass).

Dr. Sternglass, despite his lack of familiarity with the PNPP area 31/, offered his general opinion that mobile detectors mounted on land vehicles are handicapped by inaccessability to areas like railroad tracks, wooded areas, and bodies of water.

Sternglass at 8. However, there is an excellent network of roads in the vicinity of PNPP which allows effective tracking 31/ See Tr. 2692 (Sternglass).

e 6

.of the plume. Finding.37. Releases over Lake Erie which're-

- . turned to land would be tracked by Applicants' computerized dose projection system and could be detected by mobile teams along theLahore or.by DOE helicopters. . Finding 38.

-The~ Board notes that there are also two fixed independent radiation monitoring systems in-place around PNPP. The State of. Ohio and.the NRC b'oth have thermoluminescent dosimeter

("TLD") monitors arranged in rings within the plume exposure pathway EPZ. The TLD monitors measure the doses from acci-dents, as well-as any doses from normal plant operation, if'any

l. measurable doses are produced. These fixed systems are in ad-dition to the TLD monitors placed and maintained by CEI throughout the EPZ. Although these devices cannot give-instan-taneous indications, they would be valuable to measure the doses during an accident. They could be changed during an acci-dent.to evaluate doses during various stages of the accident.

Finding 39.

In conclusion, there is no regulatory requirement for fixed, off-site independent radiation monitoring systems. It was unrefuted that a fixed system for PNPP would be less effec-tive,Jand more costly, than the mobile monitoring teams which will be used. Further, the. mobile monitoring teams of the L .

State of Ohio and Lake County, the DOE, NRC and EPA mobile teams, and the fixed TLD monitors maintained by the State and E

the NRC, will provide independent radiation monitoring around PNPP. Thus, there is reasonable assurance that the public health and safety will'be protected in the event of a radiological accident at PNPP.

5. Contention P: Hospitals This contention concerns the capability of hospital medi-cal services to handle contaminated injured or exposed persons if a radiological accident were to occur at PNPP. See Finding 40.

Applicants' witnesses on Contention P were Dr. Roger E.

Linnemann and Dr. Deborah Hankins. As Vice Chairman and Chief Medical officer of the Radiation Management Corporation

("RMC"), Dr. Linnemann is responsible for the training which RMC has provided to hospitals in the area surrounding PNPP. He also is Clinical Associate Professor of Radiology, University of Pennsylvania School of Medicine, and Visiting Associate Pro-fessor of Clinical Radiology, Northwestern University Medical School. Applicants' Direct Testimony of Roger E. Linnemann on Issue No. 1 - Contention P, ff. Tr. 2980 (hereinafter "Linnemann"), at 1-2. Dr. Linnemann has actual experience treating contaminated injured and exposed patients, and has published numerous articles on the ability of hospitals to treat such patients. See Professional Qualifications of Roger E. Linnemann, ff. Tr. 2978 Tr. 2991, 2992, 3027 (Linnemann).

Dr. Ha,nkins, who has a Ph.D. in Nuclear Engineering, is Principal Engineer, Systems Engineering, The General Electric Company ("GE"). She has 13 years of nuclear experience (including experience as a senior reactor operator) and has published widely in technical journals, including several arti-cles on severe accident issues. Resume attached to Rebuttal Testimony on NUREG/CR-2239, ff. Tr. 3158 (hereinafter "Hankins"); Tr. 3167-71 (Hankins).

The Commission's emergency planning regulations require that "(a]rrangements are made for medical services for contami-nated injured individuals." 10 C.F.R. 9 50.47(b)(12).

NUREG-0654 provides that each emergency planning organization should arrange for local and backup hospital and medical ser-vices for such individuals, and should provide assurance that persons providing these services are adequately trained. Find-ing 41. The Commission has interpreted 10 C.F.R. $

50.47(b)(12) to include radiation exposed as well as contami-nated injured persons. Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 N.R.C. 528, 530 (1983). The United States Court of Appeals for the District of Columbia Circuit recently has ruled that

" arrangements" for medical services for contaminated injured and exposed members of the general public (as for on-site emer-gency workers) require more than "a simple list of treatment facilities already in place. . . ." GUARD v. United States Nuclear Regulatory Commission, 753 F.2d 1144, 1146 (D.C. Cir.

'1985). For the reasons stated below, the Board finds that sat-isfactory arrangements consistent with the GUARD decision have been made for hospital medical services in an emergency at PNPP.'

Radiation injuries result from either exposure to radia-tion or contamination by radioactive particles. In the case of radiation exposure, the patient is not radioactive and presents no hazard to response personnel. In the case of contamination, an exposure hazard remains until loose radioactive particles adhering to the body are removed. However, radioactive decon-tamination is easy to detect and is easily accomplished by re-moving contaminated clothes and bathing the affected area. The emergency plans call for people who are contaminated and not injured to go to relocation centers other than hospitals. -

Finding 42.

The characteristics of radiation injury make it one of the easiest medical emergencies to handle. Radiation injuries are seldom if ever life threatening, and their consequences unfold predictably over a period of time. No special equipment is needed for treatment of radiation injuries or disposal of any contaminated materials. Finding 43.

Should a patient be exposed and otherwise injured, the pa-tient can be handled as any other injured patient, and no 1

n .

special. emergency facilities are needed. Finding 44. If the patient.is contaminated and otherwise injured, procedures are implemented to reduce exposure and control the spread of any

. contamination. However, these procedures are not unique to ra-diation injury cases; similar steps are taken for chemical con-tamination orEseptic cases. Finding 45.

Dr. Linnemann testified that it is unlikely that an acci-dent at a nuclear plant would require a large number of hospi-tal beds. In his substantial experience at 25 nuclear power plant sites, only two cases involved multiple injuries - in each case involving two employees each. Finding 46. Dr.

Linnemann further testified that even an accident with substan-tial offsite release of radiation would not likely result in large numbers of traumatic casualties, nor would it result in the levels of radiation exposure necessary for an individual offsite to require hospitalization. Findings 47-48. At most, hospital emergency rooms might have to deal with a few cases where someone is incidentally injured and, at the same time, slightly contaminated or exposed. Finding 48. Dr. Hankins' i testimony showed that a core-melt accident at PNPP would pro-duce offsite doses less.than 25 rem even at distances as close as one mile from the Plant. Finding 54. An exposure of approx-imately 150 rem over a period of a few hours would be necessary for an individual to require hospitalization. Finding 48.

Sunflower's witnesses, Dr. Sternglass and Dr. McTrusty, presented a strikingly different picture of the consequences of a serious accident at PNPP. Dr. McTrusty in his testimony cited a Sandia National Laboratories study, NUREG/CR-2239,

" Technical Guidance for Siting Criteria Development" (November 1982) ("Sandia Siting Study") for the proposition that a worst-case accident scenario for PNPP would involve 5,500 early deaths within 60 days, 180,000 radiation induced injuries, and 14,000 cases of malignancy. McTrusty at 3.32/ Similarly, Dr.

L Sternglass cited studies which he claimed show that a severe nuclear accident could result in hundreds to thousands of indi-t- luals receiving whole body doses in the range of 100 to 1000 rads, who would require hundreds to thousands of highly spe-cialized hospital facilities. Sternglass at 13-15.

The Sandia Siting Study is not an appropriate s.ource of the number of fatalities and injuries from an accident at PNPP.

First, the study does not represent the risk of a severe nuclear power plant accident for any particular site. Consis-tent with its purpose, which was to provide technical guidance to the NRC to support rulemaking for the siting of power reac-tors, the study makes generic assumptions with respect to both 32/ These numbers are not found in the Sandia Siting Study, but appear to be numbers that were publicized by a Con-gressional subcommittee based on background calculations of ex-trerely low probability events which were made in connection with the study. Hankins at 1-2.

probability and consequences. Finding 49. Other NRC decisions have recognized that the Sandia Siting Study does not represent realistic, site-specific risks. See Duke Power Company (Cataw-ba Nuclear Station, Units 1 and 2), LBP-84-37, 20 N.R.C. 933, 982 (1984); Boston Edison Company (Pilgrim Nuclear Power Sta-tion), DD-84-5, 19 N.R.C. 542, 550 (1984).

Second, the severe consequences reported in the Sandia Siting Study were not based upon the PNPP design. The PNPP de-sign is substantially different from the design assumed in the study. Finding 50. The largest calculated consequences in the study were based on an assumed siting source term (SST 1) which is an estimate of the largest possible release of fission prod-ucts from a pressurized water reactor assuming worst case con-ditions. The SST 1 release is not a credible source term for a BWR/6 - Mark III design such as PNPP for two basic reasons.

First the PNPP design features multiple structural barriers to fission product release. Second, the Mark III pressure sup-pression containment provides effective filtration, or scrub-bing, of potential releases from the containment. Taking these mitigating design features into account drastically reduces the projected consequences of a core-melt accident at PNPP to zero early fatalities and few if any injuries requiring emergency care. Findings 51-53.

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A GE evaluation of the consequences of a core melt acci -

dent at.PNPP shows that even at distances as close as one mile from the plant,-a core melt accident produces low doses (less than 25' rem) when PNPP specific fission product releases are coupled with the PNPP site specific features. Finding 54. GE estimated the probability of such a core-melt accident at PNPP to be one in 200,000 per reactor year. Id.

Dr. Sternglass admitted under cross-examination that the studies he cited (and on which his predictions of hundreds to thousands of radiation injuries were solely based) were not based upon the PNPP design, nor did they take into account the specific design features of the PNPP containment. Tr. 2685-90 (Sternglass). Dr. Sternglass himself was unaware of the type of containment used at PNPP. Tr. 2686 (Sternglass). Earlier studies, such as the ones cited by Dr. Sternglass which pre-dicted large accident releases, ignored the features incorpo-rated-in the PNPP containment. See Hankins at 6.

Based on the above considerations, the Board concludes Lthat it is reasonable to assume that the medical responsibil-ities of a major accident at PNPP would be the treatment of a few incidentally injured and contaminated or exposed plant workers, and possibly a few incidentally injured and contami-nated or exposed members of the public.

r These cases could readily be handled by present medical

. resources. The county emergency plans identify Lake County Me-

-morial Hospital East, Lake County Memorial Hospital West, Geauga Community Hospital and Ashtabula County Medical Center as the local hospitals design'ated to handle members of the gen-eral public who may have radiation injuries. Letters of agree-ment with all of these hospitals are being obtained. Finding

55. The PNPP Plan designates Lake County Memorial Hospital

. East as the hospital to receive highly-contaminated-injured persons from on-site for initial treatment and decontamination.

Id. Extensive _ training has been provided by RMC, as well as the State of Ohio, to personnel of all these hospitals. Find-ing 56.

Dr. McTrusty's testimony questioned the ability of the Ashtabula County Medical Center ("ACMC") to handle exposed or contaminated injured persons from an accident at PNPP on two grounds. First, Dr. McTrusty made a general assertion that ACMC has inadequate medical resources for " treatment of radia-tion contamination" of even " minimal numbers" of persons.

McTrusty at 3. Dr. McTrusty's testimony gives no indication that he has any experience or expertise in evaluating or treating radiation injuries.33/ Ac discussed above, no special 33/. As noted supra, Dr. McTrusty was not able to appear at the hearing due to scheduling difficulties. His testimony was stipulated into evidence without cross-examination.

l

emergency facilities or equipment are needed for treatment of radiation exposure. Further, Dr. Linnemann testified, based on his personal visits to ACMC, that the hospital does have ade-quate facilities, equipment and supplies for handling contami-nated injured patients. Finding 58. All four local hospitals, including ACMC, are well prepared to handle such patients.

Finding 57. We find Dr. Linnemann's expert, detailed testimony persuasive.

Further, the November 28, 1984 emergency exercise demon-strated the ACMC emergency room staff's knowledge of proper decontamination procedures. Although FEMA found certain equip-ment items unavailable to ACMC emergency room personnel during the exercise, the principal piece of equipment which was unavailable - a decontamination table container with a water collection system - has now been provided to ACMC. Finding 59.

Dr. McTrusty's second point was that he was personally aware (based on interviewing "various" emergency room personnel at some unspecified point in time) of only two hours of training given such personnel at ACMC. McTrusty at 3-4. Ac-cording to Dr. Linnemann, however, ACMC personnel received eight hours of training from RMC as well as 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from the State. Finding 56. The Board finds no reason to question the credibility of Dr. Linnemann's testimony. .In addition, the ACMC emergency room staff demonstrated its preparedness to

s -. .

handle contaminated' injured persons in a recent incident at the hospital'. See Finding 60. We conclude that ACMC does have adequate. medical resources and training to handle contaminated' and injured individuals'if there were an accident at PNPP.

We'also-find that even in the unlikely event of multiple contaminated and injured personnel, the four local support hos-pitalsTwould be able to handle the increased numbers. Since

~ hospitals already have procedures to handle mass casualty situ-ations these can easily be applied to handle multiple: injured

. contaminated patients. Finding 61.

In addition-to these four local hospitals, there are some 26 hospitals in the counties around the plume exposure pathway

-EPZ which can receive and care for radiological accident cases.

a These hospitals have diagnostic and/or therapeutic radioisotope

. facilities and are thus already capable of handling radiologically contaminated and injured patients. In addition,-

the hospitals are accredited by the Joint Commission on Accred-itation of Hospitals, which requires that they have procedures to deal with the emergency management of individuals who have actual or suspected exposure to radiation or who are radioac-tively contaminated. -Finding 62. All hospitals have written disaster plans which provide for emergency patient overflow

.from;the hospitals to be handled by other hospitals. Finding 63.-

E l

l The Board finds that the four local support hospitals for PNPP have adequate medical-resources and training to handle the number of persons which could reasonably be expected to require hospital care in the event of accident at the plant. The Board concludes that the PNPP, State and County emergency plans pro-vide adequate arrangements.for hospital medical services, including assistance to injured and contaminated or exposed individuals, in the event of an accident at PNPP.

6. Contention Q: Letters of Agreement for School Buses Contention Q concerns the issue of formal letters of agreement for the use of school buses with schools outside of the plume exposure pathway EPZ. See Finding 64.

Applicants' witness was Mr. John W. Baer. As Project Man-ager for Emergency Management Services, Energy Consultants, Mr. Baer manages Energy Consultants' activities in support of the offsite radiological emergency preparedness programs for Lake, Ashtabula and Geauga Counties. Applicants' Direct Testi-mony of John Baer on Issue No. 1 - Contention Q, ff. Tr. 3047 (hereinafter "Baer (Contention Q)"), at 1; Statement of Quali-fications of John Baer, ff. Tr. 3047, at 1.

Letters of agreement will be obtained by_the Lake, Ashtabula and Geauga County Disaster Service Agencies from each of the school districts outside the plume exposure pathway EPZ t

for PNPP designated to_ supply school buses to support an evacu-ation of the plume exposure pathway EPZ. It is anticipated '

that these letters will be.obtained before. fuel load. Finding 65.

The letters currently are under development. School dis-trict officials in all the school districts involved have been informed that letters will be sought. The letters of agreement are scheduled to follow arrangements being made between CEI and the school districts for the provision of radios for the buses.

Finding 66.

There is no reason to believe that the letters of agree--

ment with school districts outside the PNPP plume exposure pathway EPZ will not be obtained in a timely fashion. The Board finds that there is reasonable assurance that the letters will be obtained prior to operation of PNPP above five percent power. 34/

34/ In any event, letters of agreement are not necessary to demonstrate reasonable assurance that emergency plans can be implemented. Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2, LBP-85-14, 21 N.R.C. (May 2, 1985), slip op. at 240.

l I

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- _ _ - - - - _ _ - . _ _ - - _ _ . _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _- _ _ - - _ _ _ _ _ _ _ _ - _ _ - _ _ - _ ._. _ . _ _ _ _1

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7. Contention U: Handling Contaminated Property at ,

Reception Center '

~

Contention U states Sunflower's claim that reception cen-ters do not have the means or facilities to handle contaminated

, i property. Applicants' direct testimony on this contsntion was presented by Mr. Baer. His qualifications are discussed supra under Contention-Q. Applicants also presented rebuttal testi- '

/ ,

mony by Mr. John Wills, who is Resident Radiological Analyst for ODSA. Tr. 3200 (Wills). _ .

The radiological emergency response plans and procedures for Lake, Ashtabula, and Geauga Counties provide for moni-toring, decontamination, and isolation of vehicles and property, at reception centers. Standard action levels have been-estab-lishedLamong the three counties-for decontamination, including decontamination of property such as personal clothing, vehi.cles and other surfaces. Findings 68-69.

These provisions of the plans are supported by Standard Operating Procedures (" SOPS"). The Ashtabula County Decontami-nation SOP and individual fire department SOPS for Lake and Geauga Counties provide guidance to fire department personnel, who are responsible for monitoring and decontamination at re-ception centers, on the handling of property and vehicles. The SOPS provide directions for monitoring and decontamination of p

l vehicles, and provide that vehicles that cannot be 4

'/-

decontaminatejd will be impounded. Personal property found to be contaminated will be sealed in plastic bags for disposal.

i_ Findings70-71.

Npproximately 554 fire department personnel have been, or will be,c trained on decontamination procedures. This is more than twice the number needed to conduct monitoring and decon-tamination activities at all reception centers. The training

,$: includes specific instruction for handling contaminated prop-erty and vehicles. Finding 72.

j,{ Emergency, kits containing equipment and supplies for moni-f.- toring, decontamination, and handling of property and vehicles currently are being assembled. Some kits are now in place, and f.

~.

( c kits are scheduled to be in place for all reception centers ,

prior to fuel load. Specific instructions will be provided with the kits directing where contaminated vehicles will be im-pounded and where contaminated property will be temporarily stored at each reception center. Findings 73-74.

- The reception centers designated in the Lake, Ashtabula 7 _and Geauga Plans are public education institutions; therefore adequate facilities are available - i.e., parking lots and rec- .

reation fields - for isolating vehicles that require decontami-y

. nation. Finding 75. Access to these areas would be restricted if contamination reached a preestablished limit. Id.

t[

The Board finds that the plans and procedures are in place for handling contaminated property at reception centers. Sun-flower's cross-examination of Applicants' and FEMA's witnesses uncovered no reason to question the adequacy of those arrange-ments. There is reasonable assurance that reception centers Lhave the means and facilitiec for handling contaminated prop-erty in the event of an accident at PNPP.

8. Contention Z: Bus Driver Protection l

Contention Z asserts that the emergency plans do not pro- l i

vide decontamination protection for bus drivers during an emer- ;

gency. Sunflower believes that bus drivers, in addition to the dosimeters they will have, should also be provided with protec-tive gear such as. respirators and goggles. Applicants' wit-nesses for Contention Z were Mr. Baer, and Mr. Wills, who offered rebuttal testimony.

There is no regulatory requirement and no regulatory guid-ance that calls for bus drivers to be provided with protective gear such as respirators and goggles. NRC regulations require e

that there be means for controlling radiation exposures to emergency workers. Guidance in NUREG-0654 describes provisions-for supplying dosimetry to emergency workers. Finding 77.

Although the State of Ohio requires that respiratory equipment must be provided to emergency workers under certain circum-stances, that requirement is being revised to eliminate the

/ ,

4

need for respiratory equipment for bus drivers. Finding 78.

In any event, about 550 respirators are available for offsite emergency workers. Finding 79.

The county emergency plans provide for the distribution of personnel dosimetry, both self-reading and permanent record types, to those bus drivers who will be serving as emergency workers. Dosimeters are reliable radiation detection devices.

l Finding 80. Each bus driver will wear dosimetry equipment at l all times. Training in the use of dosimetry has been and will continue to be provided to bus drivers. Finding 81.

SOPS for each school district require that bus drivers read their dosimeters and record their readings at least once an hour. If the bus driver's self-reading dosimeter indicates any radiation exposure, the procedures call for him to report to a monitoring and decontamination station outside the plume exposure pathway EPZ for monitoring and, if needed, decontami-

f. nation. Upon completion of a mission or shift, each bus driver j is required to turn in his or her dosimetry to be checked and i

recorded. Dosimetry records are forwarded to the county EOC and retained. Finding 82.

Mr. Shapiro in his testimony pointed out that FEMA found the Saybrook Fire Station in Ashtabula County inadequate for decontamination of emergency workers during the November 28, 1984 emergency exercise for PNPP. However, the Ashtabula Plan

includes two other facilities for decontamination of emergency workers in that county. Ashtabula County also has committed to make the necessary improvements to Saybrook or seek an alternate facility. Finding 83. The Board finds that the ex-ercise deficiency concerning the Saybrook Station does not sub-stantially affect the resolution of this contention and, in any event, is being adequately addressed.

In addition to the above, there are several other factors that reduce the chance of bus drivers being exposed to any ra-diation hazard.

First, emergency response plans have been written so that an evacuation can be completed before the release of signifi-cant radioactivity occurs. Finding 84.

Second, bus drivers will spend less time inside the plume exposure pathway EPZ than most other emergency workers, i.e.,

bus drivers leave the risk area as soon as their buses are loaded. Finding 85. Dr. Sternglass in his testimony claimed that bus ~ drivers would have to make repeated trips into contam-inated areas. Sternglass at 16. On cross-examination, how-ever, he acknowledged that he did not know the school popula-tion for the PNPP plume exposure pathway EPZ, or the number of buses required to evacuate that population, and thus could not say for certain whether. bus drivers would have to make repeated trips. See Tr. 2693-95 (Sternglass). (Indeed, Dr. Sternglass a

admitted that he did'not even know the names of the three counties within the EPZ. See Tr. 2692 (Sternglass)). In fact,

~ there are sufficient buses in the three counties to evacuate everyone needing transportation, including school students, in a single trip. Finding 86.

Third, every bus will have a radio, which will allow prompt receipt or transmission of pertinent information, including radiological information. Radiation information from radiological monitoring teams can be relayed to bus drivers.

Findings 87-88. Thus, Dr. Sternglass' testimony that dosimeters do not provide adequate protection for bus drivers because "they do not tell them in which direction to drive

[ sic] to reduce the exposure rate" is completely irrelevant.

Dr. Sternglass did not examine the communications systems of the three counties to see that there is an ability to communi-cate with. bus drivers. .See Tr. 2692-93 (Sternglass).

Dr. Sternglass also alluded to the possible existence in an emergency of " highly contaminated areas" and " lethal levels" of radiation-to which bus drivers might be exposed. Sternglass at 16. The evidence presented on Contention P showed that offsite radiation doses sufficient to require hospital emergen-cy care, let alone " lethal" doses, are highly unlikely even in a severe accident at PNPP. See, e.g., Finding 54.

Finally, Dr. Sternglass claimed that the availability of respirators-to female bus drivers would reduce the potential exposures to developing fetuses which, according to Dr.

Sternglass, are particularly sensitive to radioiodine.

Sternglass at 17. In light of the Board's discussion, supra, concerning Dr. Sternglass' credibility, it is unnecessary to further address the merits of Dr. Sternglass' theories on fetal sensitivity.

The Board concludes that, in light of the information and procedures in the emergency response plans providing for the proper dosimetry, exposure control recordkeeping, and moni-toring and decontamination services, as well as the other fac-tors discussed above, bus drivers are well protected. There is no need for bus drivers to have goggles, protective clothing or respirators.

9. Contention BB: FEMA Interim Report Sunflower's Contention BB alleges that.the offsite emer-gency plans for PNPP are inadequate due to the planning deficiencies set forth in FEMA's Interim Report on Offsite Radiological Emergency Planning for the Perry Nuclear Power

. Station, dated January 10, 1984 (" FEMA Interim Report").

Applicants' witness on this contention was Mr. Baer.

1 l

.The FEMA Interim Report concluded that "there is reason-able assurance that the plans are adequate and capable of being implemented in the event of an accident at.the site." Finding 90.

The FEMA Interim Report reflects the review by the FEMA Regional Assistance Committee ("RAC") of draft Ashtabula, Geauga and Lake County Emergency Plans submitted for review by the State of Ohio on March 17, 1983, and the schedule of cor-rections to the RAC review received by FEMA from the State on August 30, 1983. As reflected in the FEMA Interim Report, more than half of the planning deficiencies identified by the RAC were corrected and the corrective actions acccepted by FEMA in the Interim Report itself. A subsequent submittal of correc-tions to be made to the_ county plans was made by the State to FEMA on March 29, 1984. Finding 91.

Each of the county plans was revised to reflect corrective actions made in direct .;sponse to the planning deficiencies noted in the FEMA Interim Report. Finding 92. All planning deficiencies listed in the Interim Report have been corrected or are being addressed. Finding 93. The few items still being addressed primarily involve Applicants' emergency information material. Finding 94. The emergency information handbook'will be distributed prior to fuel load. Id. The NRC has reviewed Applicants' emergency information handbook and determined that l

it complies with NUREG-0654. Id.

l l

The Board finds that each of the planning deficiencies listed in the Interim Report has been, or is being, resolved.

These resolutions further support FEMA's conclusion that the county plans are adequate. Sunflower's cross-examination of Applicants', the Staff's and FEMA's witnesses elicited no sup-port for Sunflower's claim that the planning deficiencies noted in the FEMA Interim Report indicate that the county plans are inadequate.

10. Contention CC: SER Resolution Items Contention CC asserts that the resolution items set forth by the Staff in Supplement 4 of its Safety Evaluation Report Related to the Operation of the Perry Nuclear Power Plant, Units 1 and 2, NUREG-0887 (February 1984) ("SSER 4"), pages 13-1 to 13-22, are uncorrected deficiencies-in Applicants' emergency plan. The referenced pages in SSER 4 set forth the Staff's evaluation of the PNPP Plan (through Revision 2),.and identified 35 items which required resolution. Finding 95.

Applicants' witness for Contention CC was Mr. Hulbert.

His qualifications are discussed supra under Contention J.

Sunflower declined to conduct cross-examination on Contention CC. Neither did Sunflower present any direct testimony on this contention. .

On April 28, 1984, CEI transmitted to the Staff Revision 3 to the PNPP Plan, as well as a cross-reference between the res-olution' items in SSER 4 and where in Revision 3 those items had been resolved. On August 20, 1984 and October 29, 1984, CEI provided to the Staff additional clarification of changes to the PNPP Plan which related to resolution items in SSER 4 and which were being incorporated in Revision 4 to the PNPP Plan.

On February 20, 1985, CEI transmitted to the Staff Revision 4

- to the PNPP Plan. This revision incorporated the information from the August 20 and October 29, 1984 correspondence identi-fied above. Finding 96.

The information contained in Revisions 3 and 4 and the identified correspondence demonstrate that all the emergency planning resolution items in SSER 4 have been resolved. Find-ing 97. The evidence is undisputed, and the Board so finds, that these resolution items are not uncorrected deficiencies in the PNPP Plan.

B. Issue No. 16: TDI Diesel Generators

1. Background and Introduction i

Issue No. 16 concerns the ability of the four Transamerica Delaval, Inc. ("TDI") diesel generators in place at PNPP to l

reliably generate emergency onsite power. ~

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Intervenors Sunflower and OCRE filed separate diesel gen-erator. contentions. Both Applicants and the Staff opposed ad-mission of the contentions. Neither Sunflower's nor OCRE's original contention concerning the PNPP diesel generators was admitted by the Board.35/

OCRE subsequently filed a motion to resubmit its conten-tion on the diesel generators. This motion was opposed by Applicants and the Staff. .The Staff subsequently re-examined its position, in light of new information, and later supported the admission of OCRE's late-filed diesel generator contention.

The contention was admitted in this proceeding on December

-23, 1983, with OCRE as the lead intervenor.36/ As admitted by the Board, Issue No. 16 states:

Applicant has not demonstrated that it can reliably generate emergency on-site power by relying-on four Transamerica Delaval diesel generators, two for each of its Perry units.

The Board's basis for admitting Issue No. 16 was the num-ber of deficiencies. reported via Deficiency Analysis Reports

("DARs") on the PNPP TDI diesel generators which raised design,

.35/ See LBP-81-24 at 222-24.

36/ The Board simplified the contention resubmitted by OCRE.

Memorandum and Order (New Contention on Diesel Generators),

LBP-83-80, 18 N.R.C. 1404 (1983).

p as well as manufacturing concerns, and cracks in the crank-shafts in tne TDI diesel generators installed at the Shoreham Nuclear Power Station ("Shoreham").32/

' Briefs on NRC regulations and guidance applicable to Issue No. 16 were' submitted by OCRE, the Staff, and Applicants.

Reply briefs'were thereafter filed by OCRE and Applicants.

Discovery on this issue closed on June 1, 1984. It in-

- cluded three sets of interrogatories to the Applicants by OCRE and one set of interrogatories and request for production of documents to OCRE from Applicants. On January 7, 1985, OCRE filed a motion to reopen discovery on Issue No. 16 along with another set of interrogatories to Applicants. Applicants vol-untarily responded to the new set of interrogatories and pro-vided the majority of the documents requested.

On February 5, 1985, Applicants filed a motion for summary disposition of Issue No. 16. Applicants' motion was supported by~the Staff and opposed by OCRE. After considering the fil-ings of the-parties, the Board denied Applicants' summary dis-position motion.38/ The Board indicated that its decision was l'

E governed by the technical complexity of the issue.

L 37/- See LBP-83-80 at 1405-07.

i 38/- March 13, 1985 Memorandum and Order. See April 9, 1985 Memorandum and Order.

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On February 11, 1985, OCRE filed a motion to.have Mr. George Eley, an individual who had testified on behalf of intervenors in the Shoreham. proceedings on TDI diesel genera-

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tors, appointed as a Board witness in this proceeding. OCRE justified its request by citing its inability to pay Mr. Eley's fees and expenses. After considering the opposing-filings of the other parties, the Board denied this motion.39/ OCRE sub-sequently filed a motion for directed certification of the Board's decision on March 16, 1985. This motion was opposed by both Applicants and the Staff. The Atomic Safety and Licensing Appeal Board refused to delay the evidentiary hearing on Issue No. 16,40/ as.OCRE had requested, and subsequently denied OCRE's motion,41/ agreeing with Applicants and the Staff that the standard for interlocutory review had not been met.

Pre-filed written testimony on the diesel generator issue was submitted by Applicants and the Staff. OCRE filed no testimony. OCRE filed a motion to strike portions of Appli-cants' and the Staff's testimony on April 1, 1985. This motion was subsequently denied, as to Applicants (Tr. 2170), and with-drawn, as to the Staff (Tr. 2281).

29/ March 13,~1985 Memorandum and Order. See Memorandum and Order (Motion for Appointment of Board Witnesses) (March 26, 1985) (explaining the Board's decision).

, 40/L Order (April 2, 1985).

41/ ALAB-805, 21 N.R.C. (April 10, 1985).

Applicants' witnesses at the evidentiary hearing on Issue No. 16 were Edward C. Christiansen, John C. Kammeyer, and Charles D. Wood, III. Edward C. Christiansen is the Senior De-sign Engineer at PNPP responsible-for the Electrical Unit of the Nuclear Construction Engineering Section. His responsibil-ities include the coordination of engineering and licensing ac-tivities involved with the diesel generators and associated standby power facilities at PNPP. Mr. Christiansen acted as CEI's technical representative to the TDI Diesel Generator Own-ers Group (" Owners Group").

John C. Kammeyer is an employee of Stone & Webster Engi-neering Corporation who is currently acting as the Assistant Head of the-Site Engineering Office at Shoreham. Over the last

'five years his responsibilities at Shoreham have provided him with extensive experience in the resolution of problems and

-technical issues involving TDI diesel generators. Mr. Kammeyer served as the Owners Group Program Manager and had the overall responsibility for implementation of the Owners Group Design Review / Quality Revalidation Program for TDI diesel generators in nuclear service.

Charles D.' Wood, III is the Vice President of the Engines, Emissions, and Vehicle Research Division of Southwest Research Institute ("SwRI") which was employed by Applicants to indepen-

.dently review the Owners Group analyses of sixteen engine

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-components exhibiting potentially generic problems (Phase I of the. Owners Group Program). Mr. Wood has nearly 30 years of en-gineering experience with extensive work involving different -

types of diesel engines. Mr. Wood is the author of numerous publications concerning diesel engines and holis a number of patents.

The Staff's witnesses were Dr. Carl H. Berlinger, Drew Persinko, Dr. David A. Dingee, Howard M. Hardy, Adam J.

Henriksen, Dr. Spencer H. Bush, and B. J. Kirkwood.

Dr. Carl H. Berlinger is a member of the NRC Staff, currently-acting as the NRC TDI Diesel Generator Project Group Manager.

Dr. Berlinger holds a PhD in mechanical engineering and has nearlyJ12 years experience with the NRC in the Systems Integra-tion, Licensing, and Operating Reactors Divisions.

-Mr. Drew Persinko is also a member of the NRC Staff em-ployed as an Integrated Assessment Project Manager in the Li -

censing Division. Mr Persinko is a member of the TDI Diesel Generator Project Group. As such,-he has been responsible for Staff review of the TDI diesel generators at PNPP and. Comanche Peak,' and'has assisted in the reviews at a number of other plants.

Dr. David A. Dingee is employed by Pacific Northwest Labo .

ratory ("PNL") and is currently serving as Deputy Project Man-

.ager on the Assessment of Diesel Engine Reliability / Operability o

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project being conducted for the NRC Staff. Dr. Dingee holds a PhD in physics.

Howard M. Hardy, Adam J. Henriksen,.Dr. Spencer H. Bush and B. J. Kirkwood are all employed as engineering consultants to PNL. Mr. Hardy is a specialist in engine dynamic vibration analyses and has worked extensively with medium to large diesel and gas engines. Messrs. Henriksen and Kirkwood have a consid-erable amount of experience in diesel engine applications and contributed extensively to the technical evaluation of the PNPP engines' reliability / operability. Dr. Bush holds a PhD in met-allurgy.

OCRE presented no direct testimony, but cross-examined both Applicants' and the Staff's witnesses.

2. Reliability of the TDI Diesel Generators The primary focus of the Board's decision on Issue No. 16 is on the measures taken by Applicants to revalidate their TDI diesel generators 42/ in light of the design and manufacturing )

problems associated with TDI units at other plants (particular-ly at Shoreham). The Board has concluded that Applicants have 42/ The PNPP diesel generators are DSRV-16-4 engines.

Finding 100. These are TDI R-4 model engines, having 16 cylin-ders arranged in two banks in a V-type engine block, as opposed to'TDI's DSR-48 which is an inline, 8-cylinder engine design.

d.

adequately addressed the concerns raised by OCRE as to the reliability of the TDI diesel generators in place at PNPP and have demonstrated that these engines are capable of performing their intended safety-related functions.

This conclusion is based on a review of the TDI Diesel Generator Owners Group Program and Applicants' implementation thereof (including the Phase I and Phase II component reviews and the engine tear-down and revalidation performed on both Unit 1 diesel generators), and Applicants' commitment to per-form.the same type of program for the Unit 2 diesel generators.

The successful torsiograph testing of both Unit 1 engines fur-ther supports this decision. The Board also considered the ex-tensive. testing being performed on the diesel generators prior to plant operation. The Board has noted Applicants' commitment to perform the maintenance and surveillance recommendations of the Owners Group as well as those of SwRI and PNL. This com-mitment provides additional assurance of the TDI diesel genera-tors' operability and reliability in the future.

Accordingly, the Board has-concluded that Applicants have satisfactorily answered the concerns raised under Issue No. 16 and that there remains no outstanding issue as to the reliability of the TDI diesel generators in place at PNPP.

i ~ w j. , g - - ,_

I

a. The TDI Diesel Generator Owners Group Program

' Twelve U.S. utilities.(including CEI) with TDI diesel gen-erators-participated in the TDI Diesel Generator Owners Group Program. Finding 101. The Owners Group Program utilized a combination of-design reviews, quality revalidations, engine tests, and component inspections.to assess the adequacy of the PNPP TDI diesel-generators. Id. The Owners Group Program did not rely on TDI's quality assurance program. Finding 102.

Rather, the Owners Group Program, as implemented at PNPP, crevalidated the diesel generators on-site. ' Iji .

i. The Sixteen Phase I Components One of the Owners Group's first tasks was to assemble ex-perience data pertinent to TDI engines. Finding 103. Using this database, sixteen components were identified as exhibiting

.potentially generic problems; these components were singled out for.a detailed design review in the Phase I effort. Id.43/

The Owners Group reports on these " Phase I components" were reviewed by PNL for the NRC Staff. Finding 104. Appli-cants also employed an independent engineering consulting firm,

.Sb/ .These sixteen components were the turbocharger, engine base and. bearing caps, crankshaft, cyinder block, cylinder head studs, connecting rods, connecting rod bearing shells, pistons, air start valve capscrews, cylinder heads, fuel oil injection tubing,.pushrods, rocker arm capscrews, jacket water pump, wiring and termination, and cylinder liner- . Finding 103.

4

.SwRI, to review, evaluate, and independently verify the Owners

' Group methodology, results and conclusions, as reflected in each of the Phase I reports. Finding 105.44/ Based on their review, both PNL and SwRI concluded that the Phase I components in the'PNPP engines will adequately perform their intended function.45/ Findings 104, 105. The Board concurs with Appli-cants, Staff, and their consultants, and finds that the Owners Group. evaluation of the sixteen Phase I components has demon-

-strated their suitability for use in nuclear applications.

In its response to Applicants' motion for summary disposi-

-tion OCRE focused on nine of the sixteen Phase I components.4p/

It is,'therefore, appropriate for the Board to focus its dis-cussion on there same components.

44/- The Board finds both the pre-filed and oral testimony of the SwRI and PNL witnesses credible and unrefuted by OCRE.

45/ LPNL considers the PNPP crankshaft adequate provided its review of the torsiograph testing conducted at PNPP confirms the favorable results reported by Applicants. Finding 104.

PNL's interim basis for adjudging the crankshafts to be reli-

-able is the torsiograph testing previously conducted at TDI, the fact that the Owners Group analytical calculations con-

-firmed-the prior test results so closely, and the favorable re-

.sults of torsiograph testing at other plants. Finding 122.

4s/ The nine components singled out by OCRE were the crank-shaft, cylinder heads, engine base and bearing caps, turbocharger, cylinder-block, cylinder liner, pistons, con-necting rods, _and connecting rod bearing shells. At the hear-ing, OCRE focused its cross-examination on the first six of

'these components.

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' Crankshaft. As previously noted, cracks in the crank-shafts in th'e TDI' diesel generators installed at Shoreham pro-vided one of the bases for admitting OCRE's diesel generator contention in this proceeding. Problems' experienced with the Shoreham crankshafts were also the reason for including the crankshaft in the group of components subjected to a detailed design review by the Owners Group. Finding 112. The PNPP DSRV-16-41 engines are different from the DSR-48 engines in-stalled at Shoreham and also have a larger (13"-x 13") crank-

' shaft than the crankshafts (13" x 11") which cracked at Shoreham. Findings 100, 112. Both the Owners Group and SwRI concluded that the PNPP crankshafts are adequate for their intended service provided appropriate maintenance, inspection and surveillance recommendations are followed. Finding 122.

Because PNPP is committed to implementing these recommenda-tions, the Board also finds the PNPP crankshafts suitable for their intended service. Id.

The Owners Group analysis of the. crankshaft confirmed prior analysis and torsiograph testing at TDI which had indi-cated that the PNPP crankshafts met the recommendations of.the Diesel Engine-Manufacturers Association ("DEMA"). Findings 112, 113, 114. Torsiograph testing of both of the PNPP Unit 1 engines has verified this fact. Finding 114. The Board finds DEMA to be an appropriate, conservative standard for adjudging the adequacy of the PNPP crankshafts. Finding 113. It concurs 4

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with'the NRC Staff that the rules of the European ship classi-fication societies are not appropriate for stetionary diesels.

Finding.119. The Board finds that although the PNPP crankshaft has a fourth order critical speed (436 rpm) which is close to the. engines' operating speed (450 rpm), the DEMA standards have been met by a significant margin. Id. PNPP's performance specification for the engines was even more stringent than the DEMA' requirements. Finding 113. That performance specifica-tion has been met. Id. .The Board. notes, with approval, the steps taken at PNPP to limit the engines' speed range so steady operation of the engines below 450 rpm is minimized. Finding 115.

PNPP's simulation and investigation of the effect of radi-cal cylinder imbalance on crankshaft stresses (during the torsiograph testing), as well as its commitment to regularly monitor cylinder firing pressures and exhaust temperatures, ad-equately responds to OCRE's concerns regarding cylinder imbal-ance. Findings 119, 120. The Board-does not agree that cylin-der imbalance will present a problem for engine operation, as OCRE suggests.

The problems experienced with the San Onofre Nuclear Power Station (" San.Onofre") crankshaft, which were raised by OCRE at the hearing, are irrelevant to PNPP. Finding 117. San Onofre has a-DSRV-20 engine and a crankshaft significantly different from.the PNPP crankshaft Id.

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The situation at San Onofre

- _(where the engine passes through three critical speeds in close proximity) is unique, and has not been observed in any of the other:TDI engines. Id.

The Board concludes that Applicants have adequately addressed other crankshaft concerns manifested during Owners Group recommended inspections (e.g., machining marks in the oil holes).and the problems identified by regulatory reporting pro-grams (e.g., the crack in the crankshaft oil hole plug recently reported per 10 C.F.R. Part 21). Findings 116, 118. PNPP's response to the aforementioned incidents demonstrates its com-mitment to perform whatever corrective action is necessary to i

assure the continued reliability and operability of its en-gines.

Cylinder Block and Liner. At the hearing, OCRE raised a number of questions with regard to the Owners Group evaluation of the cylinder block, particularly-its inspection require-

, ments. PNPP has performed a 100 percent inspection of the cyl-4 ~inder block tops and liner landings on each of its engines and i has found no evidence of any cracking of the block tops (as oc-

curred,at Shoreham and elsewhere). Findings 123, 127. Appli- .

cants' and Staff's witnesses' testimony concerning the low

. probability of crack propagation in the blocks (even during a f

Loss,of Offsite Power / Loss of Coolant Accident (" LOOP /LOCA"))

1

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was unrefuted by OCRE. Finding 129. Abnormal microstructure was a' problem with one of the Shoreham blocks which cracked.

d Fin'ing 130. The blocks at PNPP-have been inspected and re-ported to have normal microstructure (typical Class 40 grey cast iron). Id. The Board, therefore, finds that the Owners Group recommended inspection intervals for the block are suffi-

-cient to identify any deleterious cracking prior to its presenting a problem for engine operation and concludes that the cylinder blocks at PNPP are acceptable. Findings 126-129.

The Board approves of steps taken at PNPP to reduce the possibility of block cracking by reducing liner proudness.

Finding 131. The Board finds the PNL testimony concerning the consequences of liner to block fretting convincing and does not believe it will affect operation of the PNPP diesels. Id.

Connecting Rods. The PNPP connecting rods are supplied with 1-1/2" bolts which provide a greater material section, and reduce stress levels, in the master rod box. Finding 132. The design in use at Perry does not have the failure history asso-ciated with the connecting rod-assemblies produced with 1-7/8" bolts. Id.

OCRE questioned the owners Group's failure to perform an evaluation of the buckling-strength of V-engine connecting rods, such as those at PNPP. Both the staff and its consul-tants testified that such an analysis was unnecessary in light of the absence of problems with buckling of these rods. Find-ing 133. The Board finds the testimony particularly persuasive in light of both PNL's and SwRI's review of the Owners Group evaluation of this component. Findings 104, 105. The Board, therefore,, concurs with Applicants and the NRC Staff that the connecting rods are suitable for their intended service at PNPP. Finding 134.

Connecting Rod Bearing Shells. Connecting rod bearing shells were reviewed as a Phase I component due to cracked bearing shells at Shoreham. Finding 135. The larger (1/4" x 45 degree) chamfer at Shoreham which caused the cracking has been replaced by a smaller (1/6" x 45 degree) design, which is

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utilized at PNPP. Id. OCRE conducted no cross-examination concerning the bearing shells.

The connecting rod bearings at PNPP have been inspected, per Owners Group requirements, and found to meet the Owners Group criteriaLfor acceptance. Finding 136. The bearing shells have a fatigue life of-38,000 hours0 days 0 hours 0 weeks 0 months of full load opera-tion. Finding 135. The Board finds Applicants and the NRC' Staff's testimony concerning this component credible and unrefuted by'OCRE and, therefore, finds that the connecting rod bearing shells in place'at PNPP are adequate for their intended service.

.n .

-Pistons. 'Ehe PNPP engines have AE pistons which are structurally stronger than the AF pistons'which exhibited

. cracking -. at ' Shoreham. Finding 137. OCRE conducted no cross-examination concerning the pistons. The PNPP AE piston skirts Lhave-been confirmed to satisfy Owners Group acceptance

criteria. Finding 138. Applicants and the NRC Staff.have con-cluded:that they will. perform satisfactorily. Id. No evidence has been presented by OCRE to indicate'otherwise. The Board,

- therefore,-finds that the AE pistons in place at-PNPP are ade- -

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quate for their intended service.

' Cylinder Heads. Cylinder heads were evaluated by the-Own-ers Group;as a Phase I component due.to cracking observed in a number of' locations on-the-head. Finding-157. At-the hearing, OCRE expressed concern that the PNPP cylinder heads might be

. subject to valve seat cracking. The cylinder heads in place at PNPP have all.been stress-relieved and welded to meet new requirements and are, therefore, not subject to this problem.

Finding 158. The PNPP cylinder heads also meet minimum fire deck. thickness requirements and do not have through-wall weld

. repairs performed on one side only, a condition considered-det-n rimental'by PNL due to the stress concentration associated with l

such a repair. Findings 159, 160. The Board notes with ap-

, . proval PNPP's plans to air-roll its engines after all opera-tions.and before all planned starts as an additional precaution against water leakage into the cylinders caused by possible

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_l cracking in the cylinder heads. Finding 161. The Board con-curs with Applicants and the NRC Staff that the cylinder heads in place at PNPP are adequate. Finding 162.

Engine Base and Bearing Caps. The engine base and bearing caps assembly was included among the Phase I components due to cracking observed in DSR-4 inline engines, a nut pocket failure in a DSRV-16-4 engine, and through-bolt failures on a DSR-46 engine. Finding ~163. At the hearing, OCRE indicated concern with the Owners Group inspection requirements for this compo-nent because those requirements do not include materials veri-

.fication. To ensure that the engine base is fabricated from acceptable material, the Owners Group requires inspection of the'most critical bearing saddle and the most highly-loaded bearing cap, routine maintenance, and visual inspections at each outage. Finding 164. PNPP completed these inspections and routinely performs the required maintenance, including visual inspections of every bearing saddle area. Finding 165.

During the inspection, minor casting flaws common to the type of casting involved were discovered but were too small to ne-cessitate removal. Id. The Board, therefore, agrees with Applicants and-the NRC Staff that the base, bearing caps, and associated bolting are adequate for their intended service.

Finding 166.

. s Turbocharger. IThe<turbochargers were included among the Phase I components because of a number ~of failures. Finding 167. While vane' failures may occur on the PNPP turbochargers

.in the-future,.the history of turbochargers in nuclear service

-reveals that none has suffered severe damage and?some have not even evidenced any damage as a-result of vane breakage. - Find-

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ing 169.

Because vane cracking cannot be detected-by visual or liq-uidLpenetrant inspections, the PNPP turbochargers will be sub-

jected to stringent maintenance and surveillance to identify n

any problem at an early. stage. Finding 170. The Board feels that:the' increased maintenance and surveillance to be imple-

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mentedlat PNPP is acceptable, and, therefore, finds that the iPNPP turbochargers are adequate for their intended service.

Seven Remaining Phase I Components. The remaining Phase.I.

. components (the pushrods, rocker arm capscrews, fuel oil injec-tion tubing, wiring and termination, jacket water pump, cylin-

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fder head: studs, air start valve capscrews), all received de-Ltailed design.. reviews by the Owners Group. Findings-141, 143, 145,;147, 149, 152, 155. In some-instances, SwRI performed an additional analysis or varied the-parameters in an-Owners Group analysis to reflect conditions at PNPP. Findings 141, 155. In

'all cases, the Owners Group and SwRI concluded that the compo-

- nent: utilized'at PNPP would satisfactorily perform its intended ~

r,m - , - . , . , . . , , , .- gy,- .-,,-..i- - - - . m -

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- function. Findings 141, 144, 146, 148, 151, 154,'156. OCRE a'dduced'no evidence to the contrary. The Board, therefore,

finds that each of the aforementioned components will satisfac-torily perform its intended function at PNPP.

ii. The Phase II Design. Review / Quality Revalidation Program Phase II of the Owners Group Program examined components of the PNPP engines which were not evaluated in Phase I. Find-ing 106. These components have not had a history of problems.

. Iji.

As selected by a technical committee, 171 components on the PNPP engines were reviewed in the Phase II Design Re-view / Quality Revalidation ("DR/QR") program. Id. The DR/QR

- program is based on a " lead" engine - "following" engine con-cept, with the lead engine for PNPP being a DSRV-16-4 engine at Comanche Peak Steam Electric Station (" Comanche Peak"). Find-ing-107. The Comanche Peak lead engine was subjected to an ex-tensive evaluation and detailed component review by the Owners Group.47/ Id. Results of-this investigation dictated the

~

follow-up inspections to be performed at PNPP. Id. The Board finds the lead engine approach to qualification of following

. engines to_be a valid and appropriate-technique.

---' 47/' A full, pre-operational test program has been conducted on the DSRV-16-4 engines at Comanche Peak. Finding 178. Over 100

, . hours of operation have been logged on these engines. Id.

Over'1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months have been logged on the DSRV-16-4 engines at Catawba. Id.

J k -

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w -

y e -,m--- g ,pc w % m_.wm, _ ,

, At the hearing, Applicants' witnesses responded to con-L cerns expressed by OCRE regarding the lack of quality revalidation.on various PNPP engine components. Finding 108.

The Board agrees with the Owners Group that quality revalidation of every component on the PNPP engines is unneces-sary. Where the physical inspection of a component was re-quired on the lead engine at Comanche Peak, the same inspection was performed on the PNPP engines. Id. The Board agrees with tie NRC Staff's characterization of the Owners Group DR/QR pro-gram as an " excellent revalidation program". Finding 106.

iii. ' Engine Teardown and Reassembly In the third phase of the Owners Group Program, the PNPP Unit 1 engines were completely disassembled, inspected, and re-

~

assembled under PNPP's quality control'and quality assurance program. -Finding 110. Replacement of components and routine maintenance on the engines were also performed during this time. Id.

iv. Engine Maintenance and Surveillance The final phase of the Owners Group program is ongoing at PNPP. Finding 111. It involves the implementation of a com-

.prehensive set of maintenance and surveillance recommendations.

Id. The maintenance and surveillance program being implemented at'PNPP will guarantee-that the engines meet General Design

- ~ .. .. ._ - .- - .

j ._g'-

. ,e Criteria ("GDC") 17,throughout-the life of the plant. .Id.

.This conclusion is buttressed by-the fact that PNPP has also

~

agreed.to imp 1ement each of the maintenance and surveillance

~

. recommendations:made by PNLland SwRI. Id.

The Board finds-that the' revalidation of the PNPP Unit 1 engines was complete!in scope and has been satisfactorily per-fbrmed. : Applicants have demonstrated that any inadequacies as-i'

{g sociated.with the TDI quality assurance program do not affect the reliability of the PNPP TDI diesel generators. Finding 3

, s- '102.

3

Applicants have adequately addressed each of the items highlighted by.the NRC Staff in its prefiled testimony.43/ For.

. example, the NRC. Staff indicated that it would like additional

~

'information on OCRE's previously expressed' concern regarding-the sufficiency of the contact between the engine base and chocks. Finding 173. As explained by Applicants' witnesses at r

.the hearing, . PNPP's' architect / engineer established .aul inspec-

, Etion requirement of 85% surface contact for all heavy' machinery installations. Id. An engineering evaluation was' required and 1

conducted at PNPP for chock plates with less than.85% contact.

.Id. =In all' cases,: the contact exceeded TDI's minimum J48/. In its prefiled testimony, the Staff responded to concerns

+ -raised in.OCRE's response to Applicants' motion for summary disposition.

+

h

^

r -. - . _ ._. ,_ _ _ ._ . _ _ , _ . .

requirements; hot and cold' crankshaft deflection measurements at PNPF,have confirmed that TDI's criteria have been met. Id.

b. Engine Testing The Board believes that the testing to be performed on the

. diesels prior to and during plant operation, as well as between outages,.will permit the identification and correction of any minor operational problems which occur in the diesel generators in the' future. Finding 175. As noted by one of Applicants' witnesses, random failure of components on the PNPP diesels is still.a possibility. Finding 186. Given the complexity of these engines, the Board does not find this unexpected. The Board believes that the comprehensive program conducted by the

? Owners Group has significantly reduced the likelihood of such an occurrence. Id.

,/ As of the time of the hearing, the Unit 1 engines had run

,'{ for a to.tal of approximately 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months without a hardware-

.related incident. Finding 177. This operation, coupled with the successful testing and hundreds of hours of operation accu-

[ ., mulated on other DSRV-16-4 engines, supports the reliability of 1

L DSRV-16-4's. Finding 178. The Board finds additional assur-l L ance of,the reliability of the PNPP diesels in the Owners Group study which indicated that the TDI diesel engines are extremely reliable in starting, and fall well within Regulatory Guide 1.108-_ requirements. Finding 180. The Board agrees with I ,

.i

Applicants and the NRC Staff that operation of the PNPP engines 7

for 10 cycles prior to plant operation is unnecessary.

Finding 179.

The PNPP TDI diesel generators are rated for continuous ,

operation at 7,000 kw, with a short-term overloa? rating of

.7,700 kw. Finding 100. In an accident situation, the most highly-loaded PNPP engine would be subjected to a maximum load of 5,634 kw, only 82% of the engines' nameplate rating. Find-i ing 181. The PNPP engines, therefore, have more than adequate

! design capacity to handle' the most severe design basis accident loading. Id.

3. Summary and Conclusion i.

The Board finds that Applicants have established that the Unit 1 diesel generators will perform reliably. The Unit 2 diesels will also be subjected to all phases of the Owners Group Program as carried out for Unit 1.49/ Finding 185. The Unit 2 diesels will undergo the same preoperational testing.

Id. .The Board, therefore, finds that Applicants have success-fully demonstrated that PNPP can reliably generate emergency on-site power with the TDI diesel generators installed at both PNPP Units.

49/ The Board recognizes that it may be appropriate to modify maintenance and inspection requirements, as well as some testing requirements for the Unit 2 engines, as additional op-

.erational experience is obtained. Finding 185.

FINDINGS OF FACT I. CONTENTIONS A. ' Issue No. 1: Emergency Planning

1. Contention A: State and Local Comments on ETE Study

1. Sunflower's Contention A as admitted by the Board stated:

Evacuation time estimates have not been re-viewed by State or local organizations and adverse weather conditions have not been considered.

January 10, 1985 Memorandum and Order at 6. The Board granted Applicants' motion for summary disposition of-Contention A "ex-cept as to the issue of obtaining published comments from state and local officials on evacuation time estimates. . . ." March 13, 1985 Memorandum and Order at 1. See April 9, 1985 Memoran-dum and Order at 3.

2. Appendix 4 to NUREG-0654 sets forth the regulatory acceptance criteria for evacuation time estimate studies. Ap-pendix 4 provides, in relevant part:

A review of the draft submitted by th'e.

principal organizations (State and local) involved in emergency response for the site shall be solicited and comments resulting from such review included with-the sub-mittal.

NUREG-0654 at page 4-10. See Shapiro at 3; Perrotti at 3.

3. Offsite emergency planning / response officials have played an important role in the development of the ETE for the PNPP plume exposure pathway EPZ (e.g., in the determination of preparation and mobilization times, and vehicle occupancy rates). McCandless at 2. See Perrotti at 2. Thus, the par-ticipation of these officials has gone far beyond a mere "re-view" of the ETE. McCandless at 2.

4. The evacuation time estimate study for the PNPP plume exposure pathway EPZ was pre,rared by HMM Associates, Inc. Be-fore beginning work on the Perry ETE, on October 3 and 4, 1983, HMM personnel met individually with representatives of each of the three counties (including the DSA Directors for Geauga, Ashtabula, and Lake Counties), to present the basic methodology of the ETE and to discuss the general input data and assump-tions for the computer simulation model to be used in developing the ETE. The model output (evacuation time esti-mates, average travel speeds, queue lengths, etc.) was also de-scribed. In addition, the time / weather condition scenarios to be modeled were discussed. All meeting participants were in agreement with the information presented, and future meetings with the officials were scheduled for their rev'iew of the va-lidity of the area-specific input data and assumptions for the PNPP plume exposure pathway EPZ. Id. at 1-3.

i

5. On October 17 and 18, 1983, HMM personnel again met with the officials (including the DSA Directors) of the three counties, to review the area-specific data and assumptions for i use in-the ZTE. The data and assumptions discussed included ,

1-..

matters.such;as' evacuation area boundaries, evacuation routes, 4

and adverse weather conditions to be modeled. All those in at-tendance at the meetings concurred in the results to date, as

. well as the proposed. plans and procedures for continued work on the ETE. M. at 3.

6. On March 9, 1984,-copies of the March 1984 draft of the ETE were provided to the DSA Directors and Sheriffs of each of-the three counties, and to the Ohio Disaster Services Agency. ,

("OSDA") in Columbus, for review and comment. McCandless at 3; Shapiro at'3 and Attachment 1. The agencies' comments (see Shapiro, Attachments 2-5) have been reflected in the February

~

1985 revision of the ETE, which is included in Revision 4 of the PNPP Plan as Appendix D. McCandless at 3. The comments were : submitted to the NRC on February 20, 1985 with the submis-sion'of Revision 4 of the PNPP Plan. McCandless at 3; Perrotti e

at 2; Tr. 2823-24 (McCandless), 3112-13 (Shapiro).

l-

7. On March 20, 1985, HMM met again with the three Coun-4 ty DSA Directors, who expressed concurrence with the changes made'as theEresult of their comments. Tr. 2809 (McCandless).

The County Engineers for Lake, Ashtabula and Geauga Counties 4

l also were present at that meeting, and they also concurred with the revised ETE. Tr. 2795-97 (McCandless). The ODSA also has concurred with the changes made as the result of its comments.

Tr. 2896-97 (Cole).

8. Thus, the ETE has been reviewed by the principal state and local organizations and the comments of the officials involved have been included with the submittal of the ETE to the NRC. Both FEMA's and the Staff's witnesses concluded that Applicants have complied with NUREG-0654 as it relates to this contention. See Perrotti at 3; Shapiro at 3; Tr. 3112-13 (Shapiro).

2. Contention J: Incomplete EALs

9. Contention J states:

Emergency action level indicators are imcomplete in Applicant's emergency plan.

January 10, 1985 Memorandum and Order at 6.

10. EALs describe specific plant conditions at which one of the four Emergency Classifications (Unusual Event, Alert, Site Area Emergency, General Emergency) are to be declared.

Table 4-1 of the PNPP Plan, Rev. 3 (April 23, 1984) set forth more than 200 individual EAL indications. ,

Hulb'ert (Contention J) at 2.

1 1

11. o0f the over 200 EALs, 13 were " incomplete" in Revi-sion 3 of the PNPP Plan. In each case, the value to be includ-ed later was not available at the time Revision 3 of the Plan l l

was issued, because the value could only be determined after i l

the detailed technical data became available. Id. !

i i

12. In each of the 13 cases where a value was to be added later, a comparable value was specified. For example, Table 4.1, EAL 5 I.3.a(1) stated:

Off-gas pretreatment process radiation mon-itor high alarm with indication of (1) in-crease of (later) mrem /hr in 30 min.

(equiv. to 100,000 uCi/sec).

Id.

13. In each of the 13 cases in Revision 3, either the

" missing" values have now been developed based upon additional detailed information which became available after Revision 3 was issued, or alternate indications have been selected. In all cases, these have been included in Revision 4 to the PNPP Plan, which was issued in February 1985. There are no incom-plete EALs. Id. at 2-3; Perrotti at 3-4.

14. Based on the Staff's review to date of Applicants'

. emergency classification and action level schem.e, the Staff concludes.that Applicants' emergency plan satisfies the appli-cable regulatory requirements and guidance. Perrotti at 4.

.r,. . - , _ , - - - .,y - -__,- ,, - ,, ,y --

.. +

l l

15. A' nomogram is a graphic device which contains a se-.

ries of1 assumptions and possible variables. Tr. 2648 (Sternglass). Nomograms can be developed which address a range of possible EALs'for different situations during an emergency.

See Sternglass at 4. The use of nomograms for this purpose is I

not required by any regulation. Nomograms are recommended.in

-the EPA's Manual of Protective Action Guides and Protective Ac-tions for Nuclear Incidents, at 5.15. Tr. 2648-50, 2701-04 E (Sternglass). However, the EPA Manual states that other

" shortcut" dose projection methods may have been developed that are just as accurate as nomograms; and these methods should be used if appropriate. Tr. 2703, 2728 (Sternglass).

16. Nomograms have become obsolete since the EPA Manual was written. Nomograms are not a useful tool because they re-quire a number of assumptions, are good for only a limited num-ber.of cases, and are typically difficult to read and inter-

[ pret. The current method of dose projection, which is used by Applicants, is a computer-based system which uses real time data from in-plant monitors and meteorological data for rapid dose assessment calculations. This method is far superior to nomograms'for use during an emergency. Tr. 2971-73 (Hulbert).

17. Footnote 3 of Table 6-2 of the PNPP P'lan, entitled

" Guidelines.for Protection Against Ingestion of Contamination,"

is taken from a Food and Drug Administration Federal Register

- . . . - - , _ , ,. e . .- . . , ,., ,,,

Notice containing recommendations for ingestion pathway protec-tive action guides. 47 Fed. Reg. 47073, 47081 at n. 1, 47082 (1982). See Tr. 2654-55 (Sternglass).

18. There is no relationship between ingestion pathway protective action guides, as found in Table 6-2 of the PNPP Plan, and EALs. See'Tr. 2970 (Hulbert).

.3'. Contention M: Independent Radiation Monitoring System

19. Sunflower's Contention M alleges:

Independent Data Monitoring Systems should be installed within all counties in the Emergency Planning Zone (EPZ).

January 10, 1985 Memorandum and Order at 6.

20. There is no regulatory requirement or guidance that each jurisdiction within the plume exposure pathway EPZ have independent radiation monitoring systems. Bowers at 2.

NUREG-0654, Criterion H.7 (p. 54) says that

[ejach organization, where appropriate, shall provide for off-site radiological monitoring equipment in the vicinity of the nuclear facility.

(Emphasis added.) NUREG-0654, Criterion I.7 (p. 57) states that ,

[ejach organization shall describe the ca-pability and resources for field monitoring within the plume exposure pathway Emergency Planning Zone which are an intrinsic part of the concept of operation of the facility.

. +

(Emphasis added.) This criterion does not require that each organization have its own capability, but rather that each or-ganization describe the monitoring capability on which it will rely. Bowers at 2.

21. There also is no regulatory requirement or guidance which states that any independent off-site monitoring which may be provided must be a fixed system. Bowers at 2; Tr. 3136 (Shapiro).

22. Mobile monitoring teams provide the most effective, as well as efficient, method to track and measure offsite doses. Bowers at 4. Mobile survey teams can move to the area where meteorological conditions (both wind speed and direction)

]

l- indicate the plume is located, and make measurements to define the precise plume location and the radiation levels associated with it. The mobile survey teams can use instruments to mea-sure the whole body dose rate directly, and can take special air samples to evaluate radioiodine concentrations. As the plume moves, the survey teams can follow it. Data from these actual field measurements are fed back into the dose projection models to make the projcetions and assessments more accurate.

Id. at 3; Tr. 2929-30, 2932 (Bowers).

23. The principal advantage of mobile teams is that mo-bile teams, unlike stationary monitors, are able to locate and take measurements at the centerline of the radioactive plume, i

-so-

which is necessary for meaningful dose measurements and ex S trapolations. A dose measurement at a particular fixed monitor cannot be extrapolated to project the doses at other locations, because there is no way to know whether the monitor happens to be located at.the centerline of the plume. Tr. 2927-32 (Bow-ers). Thus, although a fixed monitoring system would give in-stantaneous readouts, the data is of questionable value. Tr.

2930 (Bowers). For this reason, even a fixed monitoring system in combination with mobile monitoring would not provide any ad-vantages over mobile monitoring for purposes of dose projec-tion. Tr. 2928 (Bowers).

24. Mobile monitoring teams are more cost-effective than stationary monitoring systems. FEMA-REP-2, Guidance on Off-Site Emergency Radiation Measurement Systems (September 1980), recommends mobile monitoring teams and rejects station-ary systems because of the large numbers of sophisticated de-tectors and the telemetry necessary for such systems. Bowers at 2-4.

25. The cost for installation and operation of a fixed monitoring system at PNPP would be substantial. Approximately 100 fixed monitoring locations would be needed. Bowers at 3.

The cost of hardware - including radiation dete'ction equipment, air sampling equipment, telemetering equipment, meteorological equipment, and a central computer - and installation of the

.- o equipment would be about-$2,635,000. In addition, there would be significant costs associated with ongoing maintenance such as' calibration. Tr. 2916-19 (Bowers).

26. A fixed monitoring system would not replace any of the following dose assessment methods to be used at PNPP: the CEI and State of Ohio monitoring teams, the PNPP in-plant effluent monitors, or the State, CEI and NRC TLDs. Tr. 2958 (Bowers).

27. The State of Ohio will field three fully trained and equipped mobile survey teams in the event of a radiological emergency at PNPP. Cole at 1-2; Tr. 2845 (Cole). These State teams provide independent monitoring assessments. Shapiro at 4; Cole at 5; Bowers at 4. In addition, the local ODSA repre-sentative for Lake County has the ability to conduct field mon-itoring if necessary. Tr. 2878-(Cole).

28. Each State team is composed of one or more techni-cians from ODSA and the Ohio EPA. Team members are identified and placed on " alert" at an Unusual Event, and are dispatched at the Alert emergency stage. The response team supervisor is dispatched by helicopter to the site area to perform an aerial survey. The helicopter's response time to the.,PNPP site is about one hour and 15 minutes, and the field teams are in place 3 to 3 1/2 hours af ter the. are dispatched. Cole at 2-3.

- ~ _

s. -

29. The State monitoring teams obtain gross gamma readings which' provide the data needed'by the State's Dose As-sessment Group in the State EOC in Columbus. The information received from the monitoring teams is fed into a dedicated com-puter system in the State EOC which plots the plume and identifies plume parameters. Cole at 2, 4; Tr. 2890-91,(Cole).

30. Field monitoring teams are directed by the response team supervisor operating out of the State communications van.

The supervisor is in direct communication with the State EOC, the County EOCs, the PNPP EOF, and the State monitoring teams.

Cole at 4.

31. The State of Ohio field monitoring teams have demon-strated their ability to perform accident assessment during eight emergency planning exercises, including the November 28, 1984 exercise for PNPP. Shapiro at 5; Cole at 5. All three counties within the PNPP plume exposure pathway EPZ rely on the State's field monitoring capabilities. Cole at 5-6; Tr. 2891-92 (Cole).

32. Independent monitoring assessment also will be pro-vided by Lake County, which will maintain two fully trained and equipped monitoring teams for response to a radiation emergency at PNPP. Each team will consist of two Lake County Health Dis-trict employees who will be trained to perform both radiation and airborne activity surveys. For each team, two additional trained personnel will be available as backups. Bowers at 5.

l

. +

33. The Lake County monitoring teams will be activated at the Alert emergency stage. Team members will report to the County Health District offices in Painesville, where they will pick up the survey kits and vehicles designated for their teams. It is estimated that the teams can be dispatched and in place within 1.0 and 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months during normal working hours,and within 1.5 and 2.0 hours0 days 0 hours 0 weeks 0 months during off-work hours, after declara-tion of an Alert. The teams will communicate with the County EOC, and will perform surveys as directed by the County Radiological Officer in the EOC. Id.

34. In addition to the State and Lake County, the De-partment of Energy, the U.S. EPA, and the NRC all have capabil-ity for gross gamma monitoring, environmental sampling and analysis, independent meteorological capability, and plume identification and tracking in the event of an accident at PNPP. A central location for consolidating and coordinating all field data - the Federal Radiological Monitoring and As-sessment Center - would be set up by DOE and would relay infor-mation to the State and County EOCs, the EOF and FEMA. Cole at

5. See Tr. 2842-44 (Cole).

35. The PNPP Plan calls for two radiation monitoring teams to be dispatched at an Alert, and a third team to be dis-patched at a Site Area Emergency, to monitor the actual condi-tions downwind of the plant. Additional teams may be organized L

as the situation warrants. All these teams are staffed by Plant personnel. Bowers at 4.

36. The CEI teams will provide field monitoring capabili-ties prior to the deployment of the State and County teams.

Depending on the time of day and site staffing, teams can be dispatched and in place within 30 to 45 minutes after declara-tion of an Alert. Bowers at 5-6.

37. There is an excellent network of roads in the vicini-ty of PNPP which allows effective tracking of the plume by mo-bile teams in land-based vehicles. Tr. 2932 (Bowers).

38. Releases over Lake Erie which returned to land would be tracked by Applicants' computerized dose projection system and could be detected by mobile teams along the shore. Tr.

2958-59 (Bowers). In addition, DOE helicopters are capable of conducting offshore monitoring. Tr. 2901 (Cole).

39. There are two fixed independent radiation monitoring systems in place around PNPP. The State of Ohio and the NRC have 27 and 25 TLD monitors, respectively, arranged in rings within the plume exposure pathway EPZ. The TLD monitors mea-sure the doses from accidents, as well as any doses from normal plant operation, if any measureable doses are produced. These fixed systems are in addition to the 25 TLD monitors placed and maintained by CEI throughout the EPZ. Although these devices l

l l

cannot give instantaneous indications, they would be valuable to measure the doses during an accident. They could be changed during an accident to evaluate doses during various stages of the accident. Bowers at 6.

4. Contention P: Hospitals

40. Contention P states:

Emergency plans are deficient with respect to hospital designations and medical ser-vices as well as procedures required to as-sist contaminated individuals.

January 10, 1985 Memorandum and Order at 6. Although the word-ing of the contention itself does not explicitly limit the med-ical services and contamination assistance aspects of the issue to hospitals, Sunflower's objection which formed the basis-for this contention was restricted to hospitals.50/

41. The Commission's emergency planning regulations, at 10 C.F.R. $ 50.47(b)(12), require that:

(a]rrangements are made for medical ser-vices for contaminated injured individuals.

See also 10 C.F.R. Part 50, Appendix E, 5 IV.E. This planning 50/ See Sunflower Alliance's Particularized Objection to Pro-posed Emergency Plans in Support of Issue No. 1,, dated August 20, 1984, at 19. A contention cannot extend beyond the inter-venor's own self-imposed limitations. Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 and 2),

ALAB-675, 15 N.R.C. 1105, 1115 (1982).

standard is addressed by NUREG-0654, Criterion L.1, which pro-vides:

Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of ra-diation exposure and uptake, including as-surance that persons providing these ser-vices are adequately prepared to handle contaminated individuals.

42. Radiation injuries result from either exposure to ra-diation or contamination by radioactive materials. In the case of radiation exposure, the patient suffers injury from the en-ergy deposited in the cells during the period of radiation, but the patient is not radioactive and presents no hazard to re-sponse personnel. Contamination results from loose radioactive particles adhering to the body. An exposure hazard remains until these particles are removed. Radioactive contamination is easy to detect and decontamination is easily accomplished by removing contaminated clothes and bathing the affected area.

Linnemann at 2. The emergency plans call for people who are contaminated and not injured to go to relocation centers rather than hospitals. Tr. 2995, 2998 (Linnemann).

43. The characteristics of radiation injury make it one of the easiest medical emergencies to handle. Radiation injur-ies are seldom if ever immediately life-threate'ning. The con-sequences unfold over a period of time with predictable se-quence. Therefore, treatment of any life-threatening traumatic l

l 1

injury or serious illness always takes precedence over treat-ment of the radiation injury. Once the patient is resuscitated and stabilized, he can be decontaminated and placed in a regu-lar hospital bed. There is then time for assessment and treat-ment of the radiation injury. No special equipment is needed (such as lead-lined operating rooms, radiation resistant equip-i ment, etc.) because of the nature of radiation exposure or the conditions of its treatment. Any contaminated materials would be disposed of.following the same procedures used for nuclear medicine departments. No special equipment would be needed to handle this disposal. Linnemann at 3; Tr. 2989-90l 3004, 3029-33 (Linnemann).

44. Should a patient be exposed and otherwise injured, no special emergency facilities are needed. The patient can be handled as any other injured patient. Linnemann at 2; Tr.

2987-88 (Linnemann).

45. If the patient is contaminated and otherwise injured, procedures are implemented to reduce exposure and control the spread of any contamination. However, these procedures are not unique to radiation injury cases; similar steps are taken for chemical contamination or septic cases. Linnemann at 2; Tr.

2990-91, 3026-29 (Linnemann).

46. In Dr. Linnemann's 15 years experience at 25 nuclear power plant sites, only two cases involved multiple injuries -

in each case involving two employees. Linnemann at 6.

-47. Even a nuclear power plant accident with substantial offsite release of radiation would not involve the generation of large numbers of traumatic casualties. The only way in

'which an offsite population can be affected is through

- overexposure to radiation. Linnemann at 3. See McTrusty at 3; Sternglass at 13.

t

48. Large doses of radiation over a short period of time

. are required to initiate the first symptoms of radiation sick-ness. An exposure of approximately 150,000 millirem over-a pe-riod.of a few hours would be necessary for an individual to re-quire hospitalization. Linnemann at 3-4; Tr. 2984-86 (Linnemann). The characteristics of a' radiation release and the relative ease of decontamination.make it unlikely that any-one could receive these levels of. exposure. Linnemann at 3-4; Tr.~2984-86,.2991, 2994 (Linnemann). At most, hospital emer-gency rooms might have to deal with a few cases where someone is incidentally injured and, at the same time, slightly contam-inated or exposed. Tr. 2984-87, 3033-34 (Linnemann).

49. The Sandia Siting Study, NUREG/CR-2239, does not rep-resent the risk of a severe nuclear power plant accident for any particular site. The purpose of the study was not to eval-h

. uate risk or accident consequences for actual operating reac-tors, but to provide technical guidance to the NRC to support ,

rulemaking for reactor siting. Consistent with that purpose, l'

-, , . , _ , . _ - - . , . ,_,,_m..r,,,,,.r,_,._m..,__., ,,.,,._,,_._...__,,_,._m- . , _ . . . , , , , _ . - - , - , . _ ..__.,,,___m_..___, ,.,,,,,_,m._ ,.

. +

the study makes generic assumptions with respect to both proba-bility and consequences. Hankins at 2, 4. See Tr. 3176 (Hankins).

50. The severe consequences reported in the Sandia Siting Study were not based on the PNPP design. The PNPP design is substantially different from the design assumed in the study.

Hankins at 3.

51. The largest calculated consequences in the Sandia Siting study were based on an assumed siting source term (SST

1) which is an estimate of the largest possible release of fis-sion products from a pressurized water reactor assuming worst case conditions. The SST 1 release is not a credible source term for a BWR/6 - Mark III design such as PNPP for two basic reasons. First, the PNPP design features multiple structural barriers to fission product release. Hankins at 4-5. Second, the Mark III pressure suppression containment provides effec-tive filtration, or scrubbing, of potential releases from the containment. Realistic inclusion of fission product retention mechanisms results in negligible offsite releases of iodine and particulates. Hankins at 4-7.

52. The filtration mechanisms alone of the Mark III con-tainment reduce the fission product releases to the levels rep-resented by the Sandia Siting Study's SST 2 and SST 3 source terms. The SST 2 and SST 3 releases are two orders of J

magnitude less than the SST 1 releases, producing no early fa- a talities.and 0 to 4 early injuries. Hankins at 6, 8.

1

53. Severe accident evaluations of the BWR/6 - Mark III comparable to the PNPP specific design show releases orders of magnitude below those assumed in the Sandia Siting Study.

Those releases would cause no early fatalities and no injuries requiring emergency care. Hankins at 7.

54. A GE evaluation of the consequences of a core-melt accident at PNPP shows that even at distances as close as one mile from the plant, such an accident would produce low doses (less.than 25 rem) when PNPP specific fission product releases are coupled with the PNPP site specific features. GE estimated the probability of such a core-melt accident at PNPP to be one in 200,000 per reactor year. Hankins at 9; Tr. 3173-74 (Hankins).

55. The county emergency plans identify Lake County Memo-rial Hospital East, Lake County Memorial Hospital West, Geauga Community Hospital and Ashtabula County Medical Center as the local hospitals designated to handle members of the general-public who may have radiation uptake or exposure. Linnemann at 4;.Shapiro at 6. Letters of agreement with all.of these hospi-tals are being obtained. See Shapiro, Att. 6 at 5, 12, 15.

The PNPP Plan designates. Lake County Memorial Hospital East as the hospital to receive highly-contaminated-injured persons

. a fromonsiteforinitiaItreatmentanddecontamination. (If Lake County Memorial Hospital East were being evacuated due to ,

an accident at PNPP -- it is within the plume exposure pathway EPZ -- these persons would be taken directly to Lake County Me-

-morial Hospital West.) Definitive, long-term care for contami-nated injuries and significant radiation overexposure is avail-able through RMC's arrangements with Northwestern Memorial Hospital in Chicago, and the Hospital of the University of Pennsylvania, Philadelphia. Linnemann at 4-5.

56. In addition to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of training provided by the State, RMC has provided extensive training to personnel of both Lake County Memorial Hospitals (East and West), Ashtabula Coun-ty Medical Center and Geauga Community Hospital. The eight

~ hour training program has as its objectives to first insure that immediate emergency medical care is provided to an injured individual and, secondly, to perform appropriate decontamina-tion and contamination control techniques. The topics of the training include the biological effects of ionizing radiation, personnel protective actions, use of emergency room equipment and supplies for the contaminated patient, contamination con-trol techniques, and decontamintion and bioassay procedures.

Eight-five hospital personnel have been trained, including fif-teen physicians, fifty-three nurses, eleven nuclear medicine and radiology personnel, and six emergency medical technicians.

Linnemann at 5; Tr. 3010-13 (Linnemann).

l

?

57. The four local hospitals for PNPP, including ACMC, t are well prepared to handle contaminated'innured patients. Tr.

3007-08 (Linnemann).

i

58. Dr. Linnemann has determined, based on personal vis-its to ACMC, that ACMC has adequate equipment, facilities and supplies for ~ handling contaminated ~ injured patients. These in-clude: a radiation-emergency area designated as part of the emergency room; survey instrumentation for detection of contam-ination; dosimeters and TLDs for recording doses for hospital personnel; floor coverings; coveralls for' attendant personnel; and other supplies. Tr. 2981-84, 3007, 3016, 3025 (Linnemann).

59. The November 28, 1984 emergency exercise for PNPP demonstrated the ACMC emergency room staff's knowledge of prop-er decontamination' procedures. Shapiro at 6, 13; Tr. 3014 (Linnemann). Although FEMA found certain equipment items unavailable to ACMC personnel during the exercise (Shapiro at 6; FEMA Ex. 2 at 58-59), the principal piece of equipment which was unavailable - a decontamination table container with a water collection system - has now been provided to ACMC. Tr.

3014-15 (Linnemann).

60. The ACMC emergency room staff recently demonstrated its preparedness to handle contaminated injured persons in the

" ultimate test" for a hospital emergency room - an incident in which an individual walked unannounced into the emergency room

F and stated that she might be contaminated. The patient was properly isolated in the designated area and surveyed for con-tamination, and determined not to be contaminated. Tr.

3008-3010 (Linnemann).

61. In the unlikely event of multiple contaminated and injured personnel, the four local support hospitals would be able to handle the increased numbers. Since hospitals already have procedures to handle mass casualty situations (for exam-ple, a bus accident), these can easily be applied to handle multiple injured contaminated patients. Incoming patients would be triaged on the basis of their injuries, since traumat-ic injury always takes precedence over contamination. If addi-tional treatment rooms are necessary, the designated Radiation Emergency Area can readily be expanded. Linnemann at 6.

62. In addition to these four hospitals, there are some 26 hospitals in the counties around the plume exposure pathway EPZ which can receive and care for radiological accident cases.51/ These hospitals are capable of dealing with contami-nated and exposed individuals, including those who have been otherwise injured. All of the hospitals have diagnostic and/or therapeutic radioisotope facilities. This requires that they 51/ Dr. Linnemann's testimony on the number of available hos-pitals was an update to information contained in the State Plan. Tr. 2981 (Linnemann).

l

)

i

r . .

1 are able to handle contaminated and injured patients which could result from injuries within their own facilities. All of these hospitals (plus the four local support hospitals) are ac-credited by the Joint Commission on Accreditation of Hospitals.

The Standard V of the Commission's Accreditation Manual for Hospitals (1984) requires each accredited hospital to have pro-cedures for:

The emergency management of individuals who have actual or suspected exposure to radia-tion or who are radioactively contaminated.

Such action may include radioactivity moni-toring and measurement; designation and any required preparation of space for evalua-tion of the patient, including, as re-quired, discontinuation of the air circulation system to prevent the spread of contamination; decontamination of the pa-tient through an appropriate cleansing mechanism; and containment, labeling, and disposition of contaminated materials. The individual responsible for radiation safety should be notified.

Linnemann at 6-7; Shapiro at 6-7; Tr. 3034 (Linnemann).

63. Given the existing emergency room and radioisotope facilities in the 26 backup hospitals, these hospitals would be more than adequate to handle any conceivable patient load arising from an accident at PNPP. Linnemann at 7. In addi-tion, all hospitals have written disaster plans which provide for any emergency patient overflow from the hos'pital to be han-died by other hoepitals. Tr. 2998-99, 3041 (Linnemann).

~ - . -

!=

J

5. Contention Q: Letters of Agreement for School Buses

64. Contention Q as originally admitted by the Board al-leged that:

There are an inadequate number of buses to transport school children during an emer-gency and evacuation procedures have not ,

considered transportation obstacles which might originate with parents picking up their children at school.

January 10, 1985 Memorandum and Order at 6-7. Summary disposi-tion was granted except as to the issue of formal letters of agreement for the use of school buses with schools outside of the plume exposure pathway EPZ. March 13, 1985 Memorandum and Order at 1. See April 9, 1985 Memorandum and Order at 8.

65. Letters of agreement will be obtained by the Lake, Ashtabula and Geauga County Disaster Services Agencies from each of the school districts outside the plume exposure pathway EPZ for PNPP designated to supply school-buses to support an evacuation of the plume exposure pathway EPZ. Baer (Contention Q) at 1-2; Shapiro at 9. It is anticipated that these letters will be obtained before fuel load. Baer (Contention Q) at 2.

66. The letters of agreement with school districts cur-rently are under development. School district officials in all the school districts involved'hav~e been informe'd that letters will be sought. Tr. 3049-50 (Baer). The letters of agreement are scheduled to follow arrangements being made between CEI and

- - = . - - . - _ . -

. =

the school districts for the provision of radios.for the buses. !

Tr. 3051 (Baer). ;

6. Contention U: Handling Contaminated Property I at Reception Center '

i

67. Contention U states: -

Reception centers do not have the means or "<

7s facilities for handling contaminated prop- 't erty.

January'lO, 1985 Memorandum and Order at 7.

~~

68. The radiological emergency response plans and proce-s dures for Lake, Ashtabula, and Geauga Counties provide for mon- 7 itoring, decontamination, and' isolation of vehicles and prop-erty at reception centers. Applicants' Direct Testimony of g John Baer on Issue No. 1 - Contention U,;ff. Tr. 3055 (herein-

~'

after "Baer (Contention U)"), at 1; Shapirolat 10.

69. The emergency plans for the three counties establish standard action levels for decontamination, including decontam-ination of property such as personal cl'othing, vehicles and

~

other surfaces. Baer (Contention U) at 1-2.

70. These provisions of the plans are supported by Stan-dard Operating Procedures (" SOPS") which are maintained as sup-porting documents to the plans by the Disaster Services Agen-x cies of Lake, Ashtabula, and Geauga Counties. The Ashtabula County Decontamination SOP and individual fire department SOPS ,,

s f"

,.e

. - - - , - . , . - .~.

. +

. . l l

for Lake and Geauga Counties provide guidance to fire de-partment personnel, who are responsible for monitoring and decontamination at reception centers, on the handling of prop-f erty.and vehicles. Id. at 2; Shapiro at 10. 4 i

71. The SOPS provide directions for monitoring and decon- i tamination of vehicles, and provide that vehicles that 'cannot

^

x_ be decontaminated will be' impounded. Baer (Contention U) at 2; Shapiro at 10; Tr. 3058 (Baer). Personal property found to be V

contaminated will be sealed in plastic bags for disposal ac-cording _to the State Plan, which provides for the Ohio EPA to

~

arrange #for disposal with a licensed commercial radioactive wa.ste.dispobal firm. Baer (Contention U) at 2. See Tr.

_ 3056-57-(Baer),.; s

72. Approximately 554 fire department per.sonnel, have re-ceived, or will be scheduled to receive prior to fuel load, training on decontamination procedures based on the N'

.s Radiological Training Manual of the State of Ohio for the 16

,' Hour Radiological Monitoring Course. This is more than twice

'5 the' number; needed to conduct monitoring and decontamination ac-g; s '. ~

tivities at all reception centers. The Radiological Monitoring

. hCkurseprpvidesspecificinstructionforhandlingcontaminated AN Y ,. property andsvehicles. Baer (Contention U) at'2-3.

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s.

4

. 5

's. ~

73. \ Emergency kits containing equipment and supplies for g

x' monitoring,' decontamination,and handling of property and j' , ,

(

u e y 7 sq m, N s

e l e I

vehicles currently are being assembled. Some kits now are in place, and kits are scheduled to be in place for all reception centars prior to fuel load. Id. at 3; Tr. 3056, 3064-65 (Baer).

1

{ 74. The contents of the emergency kits are specified in applicable procedures and include survey instruments for decon-tamination monitoring (CDV-700, GM Survey Meter, CDV-715),

chargers and batteries for survey instruments, radiological monitoring handbook, equipment and supplies for decentaminating

\ {

\

vehicles, plastic sheeting and bags, protective clothing, '

masking tape, disposable towels, soaps, brushes, etc. Baer (Contention U) at 3; Tr. 3060-61 (Baer). In addition, specific instructions will be provided with the kits directing where contaminated vehicles will be impounded and where contaminated property will be temporarily stored at each reception center.

Baer (Contention U) at 3.

l

75. The reception centers designated in the Lake, Ashtabula and Geauga Plans are public educational institutions; therefore adequate facilities are available - i.e., parking lots and recreation fields - for isolating vehicles that re-quire decontamination. Id. Access to these areas would be re-stricted if contamination of the area reached a preestablished limit. Tr. 3065-66 (Baer); Tr. 3205-06 (Wills).

.7. Contention Z: Bus Driver Protection

76. Sunflower Contention Z claims:

The plans do not' provide decontamination protection for bus drivers during an emer-gency.

January 10, 1985 Memorandum and Order at 7.

77. There is no regulatory requirement and no regulatory guidance that calls for bus drivers to be provided with protec-tive gear such as respirators and goggles. 10 C.F.R.

i 5 50.47(b)(11) requires that there be means for controlling ra-diation exposures to emergency workers. Further guidance on this topic is contained in NUREG-0654, Criterion K.3, which de-scribes provisions for supplying dosimetry to emergency workers. Applicants' Direct Testimony of John Baer on Issue No. 1 - Contention Z, ff. Tr. 3069 (hereinafter "Baer (Conten-tion Z)"), at 2.

I 1

78. The Ohio' Department of Health requires that emergency l workers be provided with respiratory equipment if they are as-signed to an activity involving certain types of radioactive releases. Shapiro at 11. That requirement is being revised to effectively eliminate the need for respiratory equipment for bus drivers. Tr. 3200-01, 3207 (Wills). ,

79. Approximately 550 respirators are available for offsite emergency workers. Tr. 3075 (Baer).

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T

80. The county emergency plans provide for the distribu-tion of personnel dosimetry, both self-reading and permanent record types, and associated recordkeeping materials to those bus drivers who will be serving as emergency workers. Baer (Contention Z) at 2; Tr. 3076-78 (Baer). Dosimeters are reli-able radiation detection devices. Shapiro at 11.

81. Bus drivers have access to dosimetry at assembly areas from which they will be deployed. Each bus driver will wear dosimetry equipment at all times. Training in the use of dosimetry has been and will continue to be provided to bus drivers. Three hundred and eighty-seven of the 718 regular and substitute bus drivers have received this training. Further training sessions will take place during the summer and early fall of 1985, and periodically thereafter, both for those bus drivers who have already had dosimetry training, as well as those who have not yet been trained. Baer (Contention Z) at 2.

82. SOPS for each school district require that bus driv-ers, as well as other emergency workers, read their dosimeters

- and record their readings at least once an hour. If the bus driver's self-reading dosimeter indicates any radiation expo-sure, the procedures call for him to report to a monitoring and deconcamination station (all of which are outsi'de the plume ex-posure pathway EPZ) for monitoring and, if needed, decontamina-tion. Upon completion of a mission or shift, each bus driver

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e .

i is required to turn in his or her dosimetry to be checked and recorded. Dosimetry records are forwarded to the county EOC 7

and retained. Id. at 3.

i

83. FEMA.found the Saybrook Fire Station in Ashtabula !

County inadequate for decontamination of emergency workers dur-ing the November 1984 emergency exercise for PNPP. Shapiro at 12; FEMA Ex. 2 at 62. However, the Ashtabula Plan includes two other facilities in Ashtabula County for emergency worker decontamination. In addition, Ashtabula County has informed FEMA that it will make the necessary improvements to the Saybrook Station or seek an alternate facility. Tr. 3197-98 (Baer).

84. Emergency response plans have been written so that an evacuation can be completed before the release of significant radioactivity occurs. Baer (Contention Z) at 3; Tr. 3080 (Baer).

85. The nature of bus drivers' duties will have them spending less time inside the plume exposure pathway EPZ than most other emergency workers, i.e., bus, drivers leave the risk area as soon as their buses are loaded. Baer (Contention Z) at 3-4; Tr. 3072-74 (Baer). ,

86. There is a sufficient number of buses in the three counties to evacuate everyone needing transportation, including school students, in a single trip. Tr. 3080 (Baer).

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87. Every bus driver will have a radio in his bus which will allow prompt receipt or transmission of pertinent informa-tion, including radiological information. Baer (Contention Z) at 4; Tr. 3080-81 (Baer).

88. State, Lake County and CEI radiological monitoring teams will be reading radiation levels and can provide informa-tion through emergency management channels that can be relayed to bus drivers. Each of the three county plans provides for the dissemination of information originating with the state radiological monitoring teams. Baer (Contention Z), at 4,

8. Contention BB: FEMA Interim Report

89. Contention BB alleges:

Offsite emergency plans are inadequate due to the planning deficiencies set forth in the Federal Emergency Management Agency In-terim Report of March 1, 1984.

January 10, 1985 Memorandum and Order at 7. The FEMA Interim Report is FEMA Exhibit 1.

90. The FEMA Interim Report concluded that "there is rea-sonable assurance that the plans are adequate and capable of being implemented in the event of an accident at the site."

FEMA Ex. 1, ff Tr. 3111, found in March 1, 1984 FEMA Memorandum from Richard W. Krimm to Edward L. Jordan.

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91. The FEMA Interim Report reflects the review by the FEMA Regional Assistance Committee ("RAC") of draft Ashtabula, Geauga and Lake County Emergency Plans submitted for review by the State of Ohio on March 17, 1983, and the schedule of cor-

.rections to the RAC review received by FEMA from the State on August 30, 1983. As reflected in the FEMA Interim Report, more than half (83 out of 145).of the planning deficiencies identi-fled by the RAC were corrected and the corrective actions ac-cepted by FEMA in the Interim Report itself. A subsequent sub-mittal of corrections to be made to the county plans was made by the State to FEMA on March 29, 1984. Applicants' Direct Testimony of John Baer on Issue No. 1 - Contention BB, ff Tr.

3088 (hereinafter "Baer (Contention BB)"), at 2.

'92. Each of the county plans was revised to reflect cor-rective actions made in direct response to the planning deficiencies noted in the FEMA Interim Report. The Ashtabula Plan was revised in May 1984. The Geauga Plan was revised in

, March and July 1984. The Lake Plan was revised in June and October 1984. Baer (Contention BB) at 2.

93. .Mr. Baer's independent review of the Lake, Ashtabula, and Geauga Plans shows that, of the total of 145 planning deficiencies listed in the Interim Report, all have been cor-rected or are being addressed. Attachment A to his testimony shows the planning deficiencies noted in the FEMA Interim

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Report, those deficiencies acknowledged by FEMA to have been corrected by the August 30, 1983 State submission, those re-maining deficiencies corrected by the plan revisions made sub-sequent to the Interim Report, and where in revised plans the remaining deficiencies were corrected. Id. at 2-3.

94. The few items still being addressed primarily involve Applicants' emergency information material. Id. at 3. The emergency information handbook will be distributed prior to fuel load. Id. at 3; Tr. 3097, 3105-06 (Baer). The NRC has reviewed Applicants' emergency information handbook for PNPP and determined that the brochure complies with NUREG-0654. Tr.

3145-46 (Perrotti).

9. Contention CC: SER Resolution Items

95. Contention CC asserts:

The resolution items set forth by the staff in its Safety Evaluation Report, NUREG-0887, Supp. 4 (February 1984) pages 13-1 to 13-22, are uncorrected deficiencies in the emergency plans.

January 10, 1985 Memorandum and Order at 7. The referenced g pages in SSER 4 set forth the Staff's evaluation of the PNPP Plan (through Revision 2), and identified 35 items which re-quired resolution. Applicants' Direct Testimony'of Daniel D.

Hulbert on Issue No. 1 - Contention CC, ff. Tr. 3091 (herein-after "Hulbert (Contention CC)"), at 2.

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96. On April 28, 1984, CEI transmitted to the Staff Revi-P sion 3 to the PNPP Plan, as well as a cross-reference between the resolution items in SSER 4 and where in Revision 3 those items had been resolved. On August 20, 1984 and October 29, 1984, CEI provided to the Staff additional clarification of changes to the PNPP Plan which related to resolution items in SSER 4 and which were being incorporated in Revision 4 to the PNPP Plan. On February 20, 1985, CEI transmitted to the Staff Revision 4 to the PNPP Plan. This revision incorporated the information from the August 20 and October 29, 1984 correspon-dence identified above. Hulbert (Contention CC) at 2; Perrotti at 4-5.

97. The information contained in Revisions 3 and 4 and the identified correspondence demonstrate that all the emergen-cy planning resolution items in SSER 4 have been resolved.

Perrotti at 5; Hulbert (Contention CC) at 2. See Hulbert (Con-tention CC) at 2-7.

B. Issue No. 16: TDI Diesel Generators

98. Issue No. 16, as simpljfied by the Board, was admit-ted as a contention in this proce.eding by Memorandum and Order (New Contention on Diesel Generators), LBP-83-8,0, 18 N.R.C.

1404 (1983). OCRE is the lead intervenor on the issue and the only intervenor which participated in its litigation.

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99. Issue No. 16, as litigated, reads as follows:

Applicant has not demonstrated that it can reliably generate emergency on-site power by relying on four Transamerica Delaval diesel generators, two for each of its Perry units. ,

1 100. The four Transamerica Delaval ("TDI") diesel generators 4

installed at Perry Nuclear Power Plant ("PNPP") are DSRV-16-4 en-gines. Applicants' Direct Testimony of John C. Kammeyer on Issue No. 16, ff. Tr. 2179 (hereinafter "Kammeyer"), at 2. These are TDI R-4 model engines, having 16 cylinders arranged in two banks in a V-type engine block, as compared to TDI's DSR-48 which is an inline, 8-cylinder engine design. Id; Staff Ex. 5 at 2.1. Each engine-generator set is rated for continuous operation at 7000 kw and has a short term overload rating of 7700 kw. Staff Ex. 5 at 2.1.

101. The TDI Diesel Generator Owners Group Program, which in-volved twelve U.S. utilities, including CEI, has provided an indepth assessment of the adequacy of the PNPP TDI diesel genera-tors to perform their s&fety-related functions through a combina-tion of design reviews, quality revalidations, engine tests, and component inspections. Kammeyer at 7-8. The NRC Staff's evalua-tion of the Owners Group Program Plan concluded that it incorpo-rated the essential elements needed to resolve ' outstanding con-cerns relating to the reliability of the TDI diesel generators for nuclear service, and to ensure that the TDI diesel engines

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complied with General Design Criteria ("GDC") 1 and GDC 17. Id.

at 10; Staff Ex. 1 at 6.

102. The Owners Group Program did not rely on TDI's quality assurance program. Tr. 2240 (Christiansen, Kammeyer); Kammeyer at 14-15. Rather, the Owners Group Program, as implemented at PNPP, revalidated the diesel generators on-site. Tr. 2238 (Kammeyer),

Tr. 2318-19 (Berlinger). While the Owners Group considered TDI's evaluations and recommendations as part of the program, it did not rely on TDI input in reaching its conclusions. Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

Dingee, Howard M. Hardy, Adam J. Henriksen, and B.J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry Nuclear Power Plant, ff. Tr. 2281 (hereinafter " Staff Testimony"),

at 16.

103. The Owners Group Program was performed over a year and a-half, employed a number of nationally-recognized technical con-sultants, and involved four phases. Kammeyer at 11-25; Tr.

2181-83 (Kammeyer). Initially, experience data pertinent to TDI engines was assembled from both nuclear and non-nuclear sources; from this database, it was determined that sixteen components ex-hibited potentially generic problems.52/ Kammeyer at 11, 16-18; 52/ These sixteen components were the turbocharger, engine base and bearing caps, crankshaft, cylinder block, cylinder head studs, connecting rods, connecting rod bearing shells, (Continued Next Page)

-108-

Tr. 2238 (Kammeyer). A detailed review of these components was conducted in Phase I of the Owners Group Program to establish the adequacy of their design, address manufacturing concerns and to prepare maintenance requirements and inspection plans for them.

Kammeyer at 12. Technical consultants performed documentation re-views, analyses and established testing requirements for each.of

, the components. Id.

104. Pacific Northwest Laboratory, operated by Battelle Memo-rial Institute.("PNL"), has reviewed the Owners Group reports on the Phase I components for the NRC Staff (except for the report on the DSRV-20 crankshaft which is still in draft, but inapplicable to PNPP's DSRV-16-4 crankshaft). Tr. 2300-01, 2329 (Berlinger).

~See also Staff Ex. 5. PNL considers all of the Phase I components suitable'for full-load operation; PNL considers the PNPP crank-shaft adequate provided its review of the torsiograph testing (Continued) pistons, airstart valve capscrews, cylinder heads, fuel oil in-jection tubing, pushrods, rocker aim capscrews, jacket water

-pump, wiring and termination, and cylinder liner. Kammeyer at 11-12.

In its response to Applicants' motion for summary disposi-tion of-this issue, OCRE only indicated concerns with regard to the crankshaft, cylinder heads, engine base and bearing caps, turbocharger, cylinder blocks, cylinder liner, pistons, con-necting rods, and connecting rod bearing shells. The NRC Staff, in' turn, focused its pre-filed tes,timony on questions raised by OCRE regarding these nine components. At the hear-ing,10CRE focused its cross-examination on the first six compo-nents.

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confirms the favorable results reported by Applicants. Staff .

1

'Ex. 5 at-3.1; Tr. 2416 (Hardy). Safety Evaluation Reports

'("SERs") will be issued by the Staff for each component. Tr.

2301-02 (Berlinger).

L 105. An independent engineering consulting firm, Southwest Research In'stitute ("SwRI"), reviewed, evaluated and independently

. verified the methodology,'results and conclusions of each'of the Owners Group Phase I studies on behalf of PNPP. Applicants' Direct Testimony of Edward C. Christiansen on Issue No. 16, ff.'Tr. 2179 (hereinafter "Christiansen"), at 7-8. SwRI has ex-l tensive experience in diesel engine research of all kinds. Appli-cants' Direct Testimony of Charles D. Wood, III on Issue No. 16, ff._Tr. 2179-(hereinafter " Wood"), at 1-2. SwRI staff members who conducted the reviews were experienced in engine design and testing, metallurgy, stress analysis, fracture mechanics, and fi-

! nite elementLmodeling. Id. at 5. In some instances, SwRI made p

independent calculations using different equations, assumptions, and/or parameters. Id.; Tr. 2219 (Wood). Based on its investiga-l, - tion, SwRI c~oncluded that the 16 Phase I components in the PNPP engines'are of satisfactory design and will perform their intended L function. Wood at 86-87.

V L'

106. Phase II examined components of the PNPP engines which were not evaluated in Phase I to assess their ability to reliably j

. perform their intended functions. Kammeyer at 16. These

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I i

t components were reviewed via a design review / quality revalidation

("DR/QR") program considered to be "an excellent revalidation pro-gram" by the NRC Staff. Tr. 2409 (Berlinger). The Phase II com-ponents have'not-had a history of problems associated with them.

- Tr.-2461 (Dingee). For the PNPP engines, 171 components were se-lected byla technical committee on the basis of their criticality to engine performance, past industry and site-specific perfor-mance, as well as on the engineering judgment and expertise of the~

selection committee. Kammeyer at 16-24. Absence of adverse oper-ating experience did not necessarily exclude a component from the DR/QR process. Id. at 20. The nature of a specific component de-

- termined if a design review alone was required, quality revalidation alone was required, or both were necessary. Id. The critical. attributes of a given component, and how best to verify those attributes (e.g., analysis, inspection, or both), dictated the nature of the required review. Id. Design review and/or

. quality revalidation requirements were reflected in task descrip-

- tions prepared for each component by the Owners Group. Id. at 21.

107. The Owners Group DR/QR Program is based on a " lead" en-gine - "following" engine concept which was approved by the NRC Staff. Kammeyer at 22, Staff Testimony at 17. The lead engine for PNPP was'a DSRV-16-4 engine at Comanche Peak Steam ~ Electric

- Station'(" Comanche Peak"). Kammeyer-at 22. The Comanche Peak en-gine was subjected to an extensive evaluation and detailed compo-nent review. Id. Each of the 171 Phase II components identified

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at PNPP were evaluated to determine if the Comanche Peak engine review was applicable,.considering factors such as loading, appli-cation, and differences in design. Id. Results of this investi-gation dictated the nature of the review to be performed at PNPP, as reflected in PNPP's DR/QR Report. See, e.g., id. at 22-23.

Eleven reports (some of which address multiple components) were prepared for components unique to the PNPP engines. Id. at 23.

108. OCRE expressed concern with the lack of quality revalidation on various PNPP engine components. See, e.g., Tr.

2224; Staff Testimony at 49. Quality revalidation was not re-quired on certain components for a variety of reasons. See Tr.

2224, 2492-95 (Kammeyer). In some instances the component was not manufactured by TDI, or was a commercial grade item (e.g., nuts, bolts, seals, gaskets) purchased by TDI. Id. at 2493. The origi-nal quality revalidation for these components on the lead engine was a documentation review. Id. Once completed for the lead en-

,gine, the follow-on engines only needed to be checked to verify the component was the same. Id. at 2493-94. In other cases, maintenance and surveillance requirements incorporated any quality revalidation that was deemed necessary. Id. at 2494. In all cases, physical inspections required on the lead engine at Comanche Peak were also performed on the engines at PNPP. Id.

109. Where design review ~of a component was dictated, this task was implemented by the Owners Group technical staff.

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~

j

Kammeyer at 22. Quality revalidation of components was carried out by a special task force of PNPP personnel following require-ments established by the Owners Group. Christiansen at 9-11.

Upon completion of the DR/QR effort, inspection results, document packages, design review findings, and calculation results were re-viewed and approved by the Owners Group technical staff. Kammeyer at 24. Where results of these reviews and/or inspections indi-cated the need, additional action (e.g., component replacement, maintenance, etc.) was taken. Id.

110. The third phase of the program involved a complete disassembly of the PNPP engines, their inspection and reassembly under PNPP's quality control and quality assurance program. Tr.

2499 (Christiansen), Tr. 2182 (Kammeyer); Christiansen at 11. Re-placement of components and routine maintenance on the engines were also performed during this time. Christiansen at 7, 11, Tr..

2499 (Christiansen).

111. The final phase of the program is ongoing and involves the implementation of a comprehensive set of maintenance and sur-veillance recommendations. Christiansen at 12-13; Tr. 2183 (Kammeyer). PNPP is implementing all applicable Owners Group rec-ommendations resulting from Phase I and Phase II of the program.

Christiansen at 12. PNPP has also agreed to implement the mainte-nance and surveillance recommendations made by PNL and SwRI. Id.

at 13; Tr. 2498 (Christiansen). See Staff Ex. 4. The maintenance

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e andfsurveillance recommendations to be implemented at PNPP will

' guarantee that the engines meet GDC 17 throughout the life of the plant. Tr. 2468 (Berlinger). The NRC Staff will review PNPP's

~

implementation'of required ma'intenance.and surveillance. Id. at 2303.

112. Crankshaft. The PNPP diesel generators have 13" x 13" crankshafts. Wood at 74." While there have been no failures of J

13" x 13" crankshafts on DSRV-16-4 engines in nuclear service, smaller 11" x 13" crankshafts have cracked on three DSR-48 engines at Shoreham. Id. at 74-75. Th'e crankshaft-was, therefore, in-cludedLamong the sixteen Phase I components and subjected to.a de-tailed design review by the Owners Group. See id. at 74-81, Kammeyer at 13. The owners Group review-included a dynamic tor- -f sional analysis and a modal superposition analysis of the crank-shaft-for'PNPP. Wood at 78-80. The Owners Group also reviewed the results of torsiograph testing performed by TDI on the Grand Gulf Nuclear Power Plant (" Grand Gulf") engine. Id. at 77. The engine' type'and the crankshaft-at PNPP are of identical design to:

those at Grand Gulf. Id. at 75.

'113. The'PNPP crankshafts are. required to meet the recommen-dations of the Diesel Engine' Manufacturers Association ("DEMA").

Bd. DEMA is considered.a conservative standard for judging the adequacy of the PNPP crankshafts. Tr. 2340 (Hardy, Henriksen).

DEMA recommendsJthat no harmful torsional vibratory stresses-~ occur

-114-

e

'within five percent above and below rated speed. Wood at.75~.

4 PNPP's performance specification was even more stringent; the en-

~g ines were required to be free of all deleterious critical speeds or' torsional vibrations for any operating. speed within the range of 90%-to;110% ofLrated speed at any-load from 0 to 110% of rated' ouput. Tr. 2187 (Christiansen). The DEMA recommendations state that. crankshaft torsional. vibratory conditions shall generally be considered safe when.they induce a superimposed stress of less

.than 5000 psi, created by a single order'of vibration, or a super--

Limposed stress of less than 7000 psi, . created by- summing the major iL = orders of vibration. Wood at 75.

.114. Crankshaft stresses were found to satisfy the DEMA ,

requirements in the Owners Group analysis. Id. at 78-80. Good

-agreement was found between.TDI's calculated-stresses and the mea-sured stresses. Id. at 78. As required by the Owners Group, torsiograph testing was conducted on.both of the PNPP engines to ,

confirm the-prior analysis at TDI as well as the' Owners Group cal-

- culations. Id. at 81; Tr. 2245-46 (Kammeyer). It was. determined that the PNPP. crankshaft has a fourth order critical' speed of 436 r

j_ rpm. 'Tr. 2245.(Kammeyer). - Although 436 rpm is close.to the.en-s < .gines' operating speed (450 rpm), the stress.at this critical 1

speed is:significantly lower than the allowable DEMA standards-

~(thensingle order stress is approximately two-and-one-half-times less>than the DEMA allowable of 5,000 psi and the combined re- -

l sponse isLapproximately 4,500. psi, which-is significantly less .

-115-4 r , ,u~-+iv M ,,-h ,., 5 d. m k

, ,, d-Y . [ E . ~~S,, yry,,[,,,%-- , , - , - , - , . , . , , --,,,,....,y.., , - . _ , , . - . , - - , - - - . .

.. .J ithan the DEMA allowable of 7000 psi) and is not considered delete-rious. Id. at 2245-46, Tr.-2196L(Christiansen). The engines, therefore,. meet PNPP's specification. Tr. 2196 (Christiansen).

115. Because the fourth order critical is fairly close to the

' engines' operating speed, PNL recommends, and the NRC Staff con-curs, that-steady operation of the engines below 450 rpm should be minimized'. Staff Ex. 5 at 4.10;. Staff Testimony at 9. PNPP has, therefore, set the limit switches on the governor to limit the en-gines' speed range to -1/2% to 6% of 450-rpm during manually con-trolled operations when the diesels are not attached to the grid.

Tr. 2498 (Christiansen).

.116. Oil holes in the crankshaft are drilled through the journal, a total length of 13 inches. Tr. 2209-10 (Kammeyer). As recommended by the Owners Group, eddy curren.t' inspection of the oil holes on the crankshaft was performed-to a depth of 3 inches.

~

Id. at 2210. 'The machining marks which were revealed during this inspection were polished to a depth of 3 inches. Christiansen at.

12. Repetition of the eddy current test on the polished oil holes indicated that they were. free of defects. Id. At the hearing,

=OCRE. expressed concern over the absence of eddy current inspection

'.to.the total depth of 13 inches. See Tr. 2210. While machining Jmarks may exist at depths greater than 3 inches in the crankshaft

-oil-holes, shear stress in these regions drops off radically and, therefore, any such marks would not be detrimental to engine Joperation. Tr. 2210-(Kammeyer).

-116- ;

u

117. Minor cracking'has been observed in the main journal oil holes on the crankshaft of a TDI diesel at San Onofre. Tr. 2331 (Berlinger). At the hearing,-OCRE questioned the applicability of this problem to the crankshafts at PNPP. See Tr. 2326-31. San Onofre has a DSRV-20 engine and a crankshaft which is signifi-cantly different from the PNPP DSRV-16-4 crankshaft. Tr. 2329 (Berlinger). The problem with the San Onofre crankshaft is be-lieved to be caused by fast starts during which the engine passes through a combination of 3 critical speeds in close proximity which contribute major stress at around the 300 rpm range. Id.,

Tr.-2327 (Hardy). This situation is unique, and has not been ob-served in any of the other TDI engines. Tr. 2329-(Berlinger).

The problems experienced with the San Onofre crankshaft are irrel-

^

evant to the.PNPP crankshafts. Tr. 2409 (Hardy).

118. At the hearing, OCRE expressed concern over a crack dis-covered in a crankshaft oil hole plug at another facility. See OCRE Ex. 8; Tr. 2228-31. The problem was observed during routine

. inspection of the crankshaft. Tr. 2230 (Kammeyer). PNPP Devia-tion Analysis Report No. 231 evaluated this incident. Tr. 2228 (Christiansen); Christiansen at 25. While the PNPP engines were not identified as among those affected, PNPP will perform an inspection of all plugs to verify that they are the sixteen gauge plugs' recommended by the manufacturer. Tr. 2262 (Christiansen).

See also OCRE Ex. 8. The crack discovered in the oil hole plug-is

, not considered to be a generic crankshaft problem. Tr. 2231 l

! (Kammeyer).

i l -117-i-

l 1

.. ~

119. OCRE expressed concern with regard to the effect of cyl-inder imbalance on crankshaft stresses; the NRC Staff, in turn, felt that some degree of cylinder imbalance should be investigated in PNPP's torsiograph testing. See Staff Testimony at 25. DEMA does not require the evaluation of cylinder imbalance (one cylin-der firing stronger than another). Tr. 2333, 2339 (Hardy). The rules of the European ship classification societies, which are considered very conservative as applied to stationary diesels, generally do require such an evaluation. Tr. 2339-40 (Hardy, Henriksen). The PNPP diesels, however, are not required to meet the ship ~ classification rules and the NRC Staff does not recommend that these rules be applied to land-based units. Staff Testimony at 25. Reasons against their use include: a) the generality of such rules, which are required to cover the wide range of engine sizes and types generally operating at variable speeds, and b) the continuous duty required at sea, which is inapplicable to nuclear service. Id.

120. Tests in which fuel is cut off to one cylinder on an en-gine have been conducted at PNPP to simulate radical cylinder im-balance. Tr. 2265 (Christiansen), Tr. 2311 (Kammeyer). Cylinder imbalance can be identified by monitoring cylinder firing pres-sures and exhaust temperatures. Staff Testimony at 9. This'will be performed at PNPP. Tr. 2497 (Christiansen). It is unnecessary to provide continuous monitoring of these parameters, as suggested

-by OCRE, because severe. imbalance would be noted by periodic

-118-

e measurements. Tr. 2347 (Berlinger, Hardy). Cylinder imbalance would not present an emergency situation, as suggested by OCRE; at most, it would necessitate a planned shut-down of the engine for servicing. Tr. 2348 (Hardy).

121. TDI's specification allows individual cylinder pressures to be within plus or minus 75 psi of the average bank cylinder pressure. Tr. 2506 (Kammeyer). Based on torsiograph testing at other sites, the Owners Group has concluded that TDI's specifica-tions produce acceptable results with regard to cylinder imbal-ance. Id. at 2506-07.

122. Both SwRI and the Owners Group concluded that the PNPP crankshafts are adequate for their intended service provided inspection, maintenance and surveillance recommendations are fol-lowed. Wood at 80-81. PNPP is committed to implementing the Own-ers Group recommendations. Christiansen at 12. The PNPP crank-shaft is acceptable to the NRC Staff and PNL provided that review of the torsiograph results confirms that the stresses are below DEMA guidelines. Tr. 2416 (Hardy). The Staff's and PNL's interim basis for adjudging the crankshafts to be reliable is the torsiograph testing previously conducted at TDI and.the fact that the Owners Group calculations confirmed the prior test results so closely. Id. at 2326. Results of torsiograph testing at other plants provides an additional basis for concluding that the PNPP crankshafts will operate reliably. Id. at 2324.

-119-

r s

123.-Cylinder Block and Liner. Cylinder blocks were included amon'g the sixteen-Phase I components due to cylinder block top

~

cracking at Shoreham and elsewhere. Wood at 56. There have been

.no. reported instances of failure of either a DSR-4 or DSRV-4 en-

.gine'resulting_from cylinder block cracks. Id. at 57.

~

E124. The1 Owners Group analysis included strain gage testing, a metallurgical analysis, and tensile.and fatigue tests of the block. -Id. at 58-60. The Owners Group produced a cumulative fa--

tigue_ damage'index which accounts for. hours of operation at dif-iferentipower. levels and corresponding mean and. cycl'ic stress _at each. level. Id. at 60. The index " quantifies" (in the compara-tive sense) the-effect of different fatigue crack growth rates of-

. different' materials. Id. See also Tr. 2450 (Bush). The Owners

. Group fracture and fatigue life evaluation produced a cumulative damage _ analysis 1which applies this index and can be used to set

- future engine operation limits. Wood at 60-61.

.-125. The' Owners Group analysis was extremely conservative-in that it incorporated a number of factors of safety.and even as- _

.sumed some initial cracking of the block prior to operation. Tr.

2194-95, 2268-72 (Kammeyer). As a result of its analysis, the Own-

, _ers Group. concluded'that.the cylinder blocks were acceptable for

- use in nuclear standby service. Id. at 2193. SwRI concurred with-

' the Owners Group's' conclusion and recommendations.

z Wood at 62.

-120-

126. OCRE indicated concern with the Owne~rs Group evaluation

~o f the. cylinder' block and its recommended inspection requirements.

See, e.g., 1hr. 2194-95, 2219, 2358-74. The Owners Group-recom-

' mends-inspection of the. block after 572 hours0.00662 days 0.159 hours 9.457672e-4 weeks 2.17646e-4 months of operation at 100%

load (7,000 kw); however, even after this period of operation there would still be a sufficient margin of safety to allow engine operation at peak load, if necessary. Tr. 2195, 2220, 2269 (Kammeyer). Any minor changes in peak loading at PNPP would re-sult in only a small change in the number of hours between recom-mended block inspections. Id. at 2220. The peak engine load which would be required at PNPP in the event that loss-of-offsite power.causes a forced plant shutdown is calculated at 5,634 kw.

App. Ex. 16-1; Tr. 2241 (Christiansen). Cumulative damage to the block (as calculated using the Owners Group cumulative damage analysis) at Loss-of-Offsite Power / Loss of Coolant Accident

(" LOOP /LOCA") load is less than 50% of that' expected at 100% load.

Tr. 2219-20 (Kammeyer).

127. The Owners Group recommends that cylinder blocks with known or acsumed ligament cracks should be inspected for stud-to-stud cracks after any operation in excess of 50% of nameplate loading.. Tr. 2370 (Bush); Wood at 62. The Owners Group believes that any stud-to-stud indications found which extend less than 1.5" from the block top are acceptable. Tr. 2372 (Bush); Wood at

62. Dr. Bush, one of the NRC Staff witnesses, disagrees with this Owners Group conclusion; he would limit the indications to 0.4" to

-121-

_ 1.

g- .

e O.'5"in the presence o'f' ligament cracks.

~ '

Tr. 2372-74'(Bush).

PNPP's 100. percent inspection of cylinder block tops and liner land'ings found.no evidence of any cracking of the block tops. Tr.

2222 (Christiansen, Kammeyer).

.128. Analysis and experience indicates that ligament and stud-to-stud cracks initiate on the surface of the blocks and would,'therefore, have been identified in the inspection performed at PNPP. Tr. 2262 (Kammeyer), Tr. 2413-14 (Berlinger, Bush).

Even if cracks initiated sub-surface, they would.quickly propagate to the surface where they would be detectable. Tr. 2413 (Berlinger).

129. Calculations indicate that it would take a very long time for ligament or stud-to-stud cracking to initiate in the cyl-inder block under conventional operation. Tr. 2441 (Bush)- . If cracks did initiate, only limited growth would be expected, even during a LOOF /LOCA event. Id. at 2440-41, 2451. While the proba-bility of crack initiation i.s quite high, the compressive stress fields would prohibit crack propagation. Id. at 2368.

130. OCRE indicated concern regarding the material properties of the cylinder blocks. See, e.g., Tr. 2351-52. The presence of abnormal microstructure (e.g., Widmanstaetten graphite, as found in one of the cracked Shoreham blocks) in large amounts is easily detected. Tr. 2449 (Bush); Wood at 59. While minor amounts could occur within the block and not be readily detectable, minor

-122-

n amounts of' abnormal micr'ostru'ctur'e wosid'also not be of much sig-nificance. Tr. 2449 (Bush). The Owners Group and SwRI recom-mended that the PNPP cylinder blocks be~ subjected to metallurgical evaluation to verify that the microstructure is characteristic of-typical grey cast iron. Wood at 62. PNPP's engine program has incorporated all of the applicable Owners Group recommendations generated in Phase I of the program. Christiansen at 7. The PNPP blocks have.been reported to have normal microstructure (typical Class 40 grey cast iron). Tr. 2351-52 (Persinko), Tr. 2410-11 (Bush, Berlinger, Dingee).

131. OCRE indicated concern with the possibility of liner to block fretting and loss of liner crush on the PNPP engines. See Tr. 2358; Staff Testimony at 42. Liner-to-block fretting is an undesirable condition, but would be very unlikely to lead to fa-tigue failure of the block or liner. Tr. 2358 (Bush, Henriksen).

Cylinder liner proudness has been reduced at PNPP to reduce the pressure on the liner and thereby reduce the possibility of block cracking. Tr. 2447-48 (Henriksen, Persinko), Tr. 2508 (Chris-tiansen). Cylinder liner proudness has been reduced down to two mils, thereby maintaining liner crush. Tr. 2448 (Persinko);

Tr. 2508 (Christiansen).

132. Connecting Rod. The connecting rod was evaluated as a

~

Phase I component because of the failure history associated with assemblies produced with 1-7/8" bolts. Wood at 82. PNPP is

-123-

D

~.

su'pplied withl h'e'new des'ign'which u dli5es 1-1/2" bolts.

~

Id.

The change in bolt diameter provides a greater material section,

^

and re' duces stress levels, in the master rod box. Id. There have been no failures with the 1-1/2" bolts at the currently-specified torque. level. Tr. 2435-37 (Berlinger).

133. In its evaluation of this component, the Owners Group identified the failure mechanisms and performed a finite element stress analysis to predict performance in nuclear applications.

Wood at 83-84. Results were compared to experimental data and operating history. Id. at 84. There is no history of buckling of V-engine connecting rods; the Staff does not recommend a buckling strength analysis. Staff Testimony at 32; Tr. 2435 (Henriksen).

Nor have there been any failures of a wrist pin bushing in a TDI engine. Staff Testimony at 32-33.

134. The NRC Staff concurs with the Owners-Group and SwRI that the PNPP connecting rods are suitable for their intended ser-vice. Staff Testimony at 6, Wood at 84-86. As required by the Owners Group and NRC Staff, preventative maintenance, including bolt torque checks, will be performed at PNPP. Tr. 2489-90 (Christiansen). See also Staff Testimony at 6, Wood at 86.

135. Connecting Rod Bearing Shells. Connecting rod bearing shells were reviewed as a Phase I component due to cracked bearing shells at Shoreham. Wood at 21-22. The large (1/4" x 45 degree) chamfer at Shoreham which caused the cracking has been replaced by 1

-124-

c .. .

b +-

e-

a smaller (1/6" x'45 deg'r'ee') design.

~

.Id. at"22. Tlie PNPP engines

^

'have the small'er-chamfer. Id. 'The Owners Group evaluation in-cluded journal, orbit analysis, tensile properties tests,. finite s-element. stress-analysis and a fracture mechqnics analysis. Id.

at}b',,s.

22-23. SwRI performed an additional' analysis to calculate oil \;

s film: thickness - and pressure for the higher peak'7 cylinder firing

~

i~ -

, o. '

. pressure in'the PNPP' engines. Id. at124-25. SwRI agreed with'the Owners' Group conclusion that the PNPP bearing shells <have a fa-

~tigue life of 38,000 hours0 days 0 hours 0 weeks 0 months of full-load operation. Id..at 25. w

'l 136. The connecting rod bearings in place at PNPP have been inspected, per Owners Group requirements, and found to meet the Owners Group criteria for acceptance. Id. at 26; Tr. 2440 (Henriksen). The NRC Staff believes.that bearings which meet the

-Owners Group acceptance criteria are adequate for their intended s'ervice . Staff' Testimony at-36.

-137. Pistons. Piston skirts were included among the Phase I components due to cracking ~in the skirt-to-crown stud attachment bosses in AF pistons at Shoreham. Wood at 49. The PNPP engines

.have AE pistons.

Id. at 50. Due to a difference in heat treat-ment / cooling rates, AE piston skirts have only one-half the amount

.of ferrite as AF pistons. Id. at 51. The lower ferrite makes the

.AE skirts structurally stronger. Id.

138. The Owners Group evaluation of the piston included de- -

structive and non-destructive examinations of a failed AF piston,

-125-

vs 1

~

. experimental stress'analysii "and finite element analysis. Id. at f '" , 50-53. The Owners Group and SwRI concluded that the AE piston c ~

s .

- skirts are adequate for unlimited life under. full load conditions.

T ;' ~

.rj Id. at 55. The PNPP AE piston-skirts have been confirmed to sat-ish'y Owners Group acceptance criteria. Staff Testimony at 27.

The NRC Staff concludes that they will perform satisfactorily.

x Id. at 28.

q.

139. OCRE expressed concern over fretting in AE pistons and instances of chrome flaking. See, e.g., Staff Testimony at 26.

The instances of fretting that have been observed between the crown and skirt of AE pistons have not been serious. Tr. 2426-27 (Henriksen); Staff Testimony at 26. Nor have any instances of chrome flaking from piston rings and. wrist pins resulted in any serious damage. Staff Testimony at 26.

140. Pushrods. The PNPP pushrods are of the friction-welded design. Wood at 38. No failures have been reported for this de-sign. Id. Problems with two other designs (" forged head" and "ba[I end") resulted in the inclusion of pushrods among the Phase I components. Id.

141..The Owners Group investigation of the pushrod included metallurgical, fatigue and buckling stability / wear resistance analyses of the various designs. Id. at 38-39. SwRI extended the Owners Group buckling analysis to include buckling under dynamic loading conditions. Id. at 39. The Owners Group analysis of

-126-

t .

e critical loading yielded safety factors of 6.1 and 2.3 for the in-take and exhaust cushrods and 2.1 for the exhaust intermediate pushrod. Id. at 40. The fatigue crack analysis indicated that, under cyclic loading, any potential fabrication crack is not ex-pected to propagate in either the main or intermediate friction-welded pushrods. Id. Non-destructive examinations performed be-fore and after fatigue testing of the intermediate pushrod showed I

no flaws. Id. at 40-41. The metallurgical evaluation of the J friction-welded design showed typical microstructures for the ma-terials. Id. at 41. Based on its analysis, the Owners Group con-cluded that the friction-welded design is the most reliable; SwRI concurred. Id. at 42.

142. PNL has also concluded that the PNPP pushrods are ade-quate for their intended service, given their favorable operating history and the satisfactory results obtained in PNPP's liquid

/ penetrant examination of its pushrods. Staff Ex. 5 at 4.24-4.25.

/ As required by the NRC Staff, PNPP will confirm that the Owners 3

IGroup requirements regarding random sample testing of the pushrod have been followed.

Tr. 2499 (Christiansen). See also Staff Testimony at 10.

143. Rocker Arm Capscrew. Rocker arm capscrews were evalu-ated as a Phase I component due to isolated failures resulting from insufficient preload application. Wood at 6. The Owners Group analysis included a fatigue life analysis, thread distortion

-127-

P analysis, thermal stress evaluation, and a determination of the applied stress and endurance limits of the two capscrew designs in use. Id. at 7.

144.' Based on their analyses, both the Owners Group and SwRI concluded that the rocker arm capscrews utilized at PNPP are ade-quate for nuclear service. Id. at 10. Maintenance will assure that loss of preload does not occur. Id. at 10-11. Based on PNPP's inspection of this component, analytical evidence and fa-1 vorable operating history, PNL also concluded that the capscrew is suitable for use at PNPP. Staff Ex. 5 at 4.27.

145. Fuel Oil Injection Tubing. Fuel oil injection tubing was reviewed as a Phase I component due to problems with leakage.

Wood at 11. The Owners Group analysis included an investigation of applied stresses on the tubing and comparison with its yield strength and endurance limits, as well as a fracture mechanics

} analysis. Id. at 12.

146. Both the Owners Group and SwRI concluded that the tubing in place at PNPP is adequate for continued use; this determination was based, in part, on PNPP's inspection of its tubing using eddy current techniques to assure the absence of flaws. Id. at 13-14.

Christiansen at 7. PNL concurs that-the tubing is suitable for its intended use. Staff Ex. 5 at 4:33.

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y..-

.147. Wiring and Termination. Wiring and termination were in-cluded as Phase I components as a result of TDI's identification of.two potentially defective engine-mounted cables that did not meet IEEE-383-1974 standards. Wood at 27. The Owners Group per-formed an' evaluation of both TDI-generic and PNPP-specific de-signs. Id. The analysis included a review of the circuit requirements, including a determination of the wire insulation rating, type and rating of termination, voltage, maximum tempera-ture, flame retardancy-requirements and routing. Id.

148. The Owners Group analyses resulted in a conclusion that the PNPP wiring and termination are satisfactory; SwRI agreed with this conclusion. Id. at 28-29. PNL concurs that PNPP's wiring and termination are suitable for their intended use. Staff Ex. 5 at 4.36.

149. Airstart Valve Capscrew. The'airstart valve capscrew was evalua'ted by the Owners Group as a Phase I component because capscrews supplied to one utility by TDI were too long for their bolt holes; this prevented the valves from being properly seated.

Wood at 34. A stress and dimensional analysis was performed for the capscrew by the Owners Group. Id. SwRI also performed a num-ber of analyses to evaluate the functional attributes of the cap-screw, with no significant difference in results from those 1

obtained by the Owners Group. Id. at 35-36.

-129-

c I150. PNPP has inspectad the bolt hole depth for'every airstartivalve capscrew on its engines to verify that they are the appropriate _ length;so that the.capscrews will not bottom out.

Tr.

~ 2223-(Christiansen), Tr. 2420-21 (Persinko).

~

151. Both SwRI and the Owners' Group concluded that the

, airstart valve capscrew was of adequate design and satisfactory.

ifor nuclear service . Wood at 36. PNL concurs that tdum capscrew design isfadequate. IStaff.Ex. 5 at 4.35.

i 152.: Cylinder Head Studs. Cylinder head studs were evaluated

- as a' Phase I component by the Owners Group due to isolated fail-ures as a result of insufficient'preload. Wood at 29. A stress

, analysis.of both head designs (" straight".and " necked" shank) was L

performed by the Owners: Group. Id. at 30. SwRI's review of the Owners Group results did not yield any significant differences.

'Idf. . at 31.

153.-PNPP has. performed the Owners Group' recommended material

~

. verification and confirmed that its cylinder head studs-meet-AISI 41401 standards. 'Id. at 32-33.

v-

.f . 154. Both-the Owners Group and SwRI concluded that either cylinder head stud design is satisfactory. Id. at 32-33. PNL

' concurs ' . Staff Ex. 5 at 4.23. The " necked" design (utilized at

^

PNPP)_was recommended by SwRI because'it is less likely to lose

- its preload,_has a higher safety factor under fatigue loading and:

r

, -130-2 e +e- . . - - - . . , . , , - - - . , , . . , - ,, ~,n ,----,..,-r -- -v-m+ . . ~ . . - - ---,-----~c . .,-

e

': lowers th'e'stressesfin the'bl6ck'adjac'ent t'o Ehe' liner landing.

Wood at 33. Maintenance will assure preload is maintained. Id.

155. Jacket Water Pump. The 'j acket water pump used on DSRV-16-4 engines does not have a history-of failures. Id. at 69.

The jacket water pump received a detailed design review by the Owners Group due to' failures on the inline, DSR-48 engines at

. Shoreham. Id. The Owners Group analysis included a torsional analysis and a stress analysis. Id. at 70-71. In conducting its

- review of the Owners Group analysis, SwRI took into account the smaller diameter of the PNPP pump impellers. Id. at 73. SwRI also considered impeller rotation and the effects of stresses due 4

to centrifugal force on the drive fit. Id.

156.-Based on its analysis, the Owners Group concluded that the pump design at PNPP was adequate for nuclear service. Id.

at 71. SwRI concurred with the Owners Group evaluation as it ap-plied to PNPP. Id. at 73. PNL.also concurs with the Owners Group evaluation. Staff Ex. 5 at 4.31.

157. Cylinder Heads. Cylinder. heads were evaluated by the Owners Group as a Phase I component because of cracking observed 1

in-a number of locations en the heads. Wood at 44. The Owners

. Group evaluation included a metallurgical analysis, an evaluation

- of thermal and pressure stresses on the head and modeling of the component. Id. at 44--46.

4

-131-o- . . . . _ --

. c

[ -c.:6 - , ,-

"158.7 Th'e" cylinder' heads 'in 'tise at?PNPP"have all' been stress-relieved and welded to meet new requirements. Staff Testimony at 6;_Tr. 2234-35 (Kammeyer). Because of this treatment, the PNPP cylinder heads are not subject to valve seat cracking, a concern raised by OCRE at the hearing. Tr. 2232-35 (Kammeyer).

159. PNL. considered it important that none of the PNPP heads have through-wall weld repairs performed on one side only, due to the stress concentration associated with such a repair. See Staff Ex. 5 at 4.20. The cylinder heads in place at PNPP do not have such weld repairs. Tr. 2428-29 (Berlinger).

160. All of the cylinders meet minimum fire deck thickness requirements, a concern raised by OCRE. Tr. 2431 (Kirkwood).

161. The PNPP engines will be air-rolled after all operations and before all planned starts to check for possible water leakage into the cylinders from cracking in the cylinder heads. Tr. 2489, 2501 (Christiansen). See also Staff Testimony at 6.

162. The Owners Group and SwRI concluded that the class of heads used at PNPP are adequate. Wood at 48. The cylinder head design is considered adequate by the NRC Staff and PNL based upon experience history as well as the analytical modeling performed by the Owners Group. Tr. 2427-28 (Berlinger, Henriksen). Inspec-

-tions to be performed on the heads provide additional assurance of their acceptability. Id. (Berlinger).

-132-1

.. . .- . . - . . . . .~ . .. .

t

n. .v e . '

.lI63.?Enclini Bise anW B'earihg ' Caps.~ '.The" engine Aas'e and ~

bearing; caps assembly.was. included among the' sixteen Phase I com-ponents'due to' cracking observed'in DSR-4 inline engines, a nut

. pocket-failure inla DSRV-16-4 engine, and through-bolt failures on a DSR-461 engine. Wood at 116. The Owners' Group performed a-fa-

. _tigue'and fracture analysis and stress analysis for both the sad---

-dle and caps. Id. at'16-17. The-through-bolts and bearing cap l -and fastener system were'also evaluated. Id. at 18-19. SwRI's review'of1the,0wners Group analysis indicated that the interface

.between the cap and saddle was even stronger than calculated ~by I

(the Owners: Group. Id. at 19. This means that-there will be no'

~

' lateral movement of the cap under the influence of the crankshaft-horizontal ~ force. Ijd. ' at 19-20.

164. OCRE questioned the absence of metal'lurgical or chemical t

composition 1 analyses of the base. See, e.g., Tr. 2216. Only one

^

isolated failure due to material abnormalities has ever been re-ported in the hundreds of engines in operation. Tr. 2216-(Kammeyer). . Metallurgical cn chemical composition evaluations were deemed unnecessary by the Owners Group due to low loading on the engine base and its favorable operational history. Tr.

2216-17, 2504-05-(Kammeyer). The.NRC Staff.and PNL. agree with

'this conclusion. Staff Testimony-'at 37-38. Any crack which did initiate in the engine base would propagate.very slowly, if at.

fall. Tr. 2442 (Berlinger). Inspection.of the most highly loaded

j. bearing cap and most highly stressed saddle, coupled with routine 1.

-133-

.m,,, ,r.,,. - - , , . - . - ~ , - . _ - , , . , . . . _ . - , , . . _ , -...-__...m. - - _ , ym..,.. . ,,, ,~ - , , ,,

e

"' ' " malhb ba'nce aNd iisiial'insp'ectio'ns'aE each outage is sufficient to

~

ensure the base is fabricated from acceptable material. Tr. 2216 (Kammeyer).

165. PNPP routinely performs maintenance for this component which includes visual inspection of every bearing saddle area on both engines. Id. at 2238-39, 2260. Inspection of the critical saddle and cap at PNPP revealed minor casting indications common to the type of casting involved. Id. at 2216, 2218. Because of the large factor of safety (greater than 15.8) against growth of such small indications, it was considered unnecessary to remove them. Id. at 2218. Both the NRC Staff and PNL agree that the in-dications are not a cause for concern. Staff Testimony at 38.

166. The NRC Staff agrees with the Owners Group and SwRI that the base, bearing caps, and associated bolting are adequate for their intended service. Id. at 37, Wood at 20.

167. Turbochargers. The turbochargers were included among the Phase I components becauseoof thrust bearing, nozzle vane, nozzle ring capscrew and washer, and nozzle ring failures on TDI nuclear standby diesel engines. Wood at 64. The Owners Group performed a number of analyses to determine loading and the load carrying capability of the turbocharger components. Id. at 64-65.

Thrust bearings were also examined for wear. Id. at 65. The Own-ers Group analysis of nozzle ring capscrew, washer and vane fail-ures determined the probable cause of the single ring failure and

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^

' Nozzie' vane lailures'; ' the -cause' of the ' cracked washer was not

~

' ~

found; however,' failure of a washer would not degrade engine per-formance. Jjg. ~-at 67. .

168. While vane failures in the steady-state operation of an engine may be predictable with some accuracy, early operational failures or. fatigue-failures cannot be predicted at this time.

Tr. 2357-58 (Bush).

169. Operational experience indicates that vane failures may occur on the PNPP turbochargers in the future. Staff Testimony at 39. While vane breakage could severely damage or demolish the rotor, the history of the turbochargers in nuclear service reveals that none have suffered severe damage and some have not even evi-denced any damage as a result of vane breakage. Id. at 40; Tr.

2443-45 (Henriksen).

170. Vane cracking, which initiates below the surface of the hub in the vane root, cannot be detected by visual or liquid penetrant inspections. Tr. 2353-54 (Berlinger). Because sub-

. surface cracking is not identifiable by inspection, the turbocharger will be subjected ~to stringent maintenance and sur-veillance to identify any problem at an early stage. Tr. 2470-72 (Berlinger, Dingee), Tr. 2490 (Christiansen).

171. The NRC Staff considers the turbochargers' alignment adequate to prevent vibration problems. Staff Testimony at 6.

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m-Pre-opera'ionai t vib' ration tests will be run on the PNPP t'urbochargers. Tr.'2445-46 (Dingee), Tr.'2251 (Kammeyer).

172. OCRE felt that the Dresser Style 65 couplings on the PNPP engines should be. replaced prior to plant operation. See Staff Testimony at 52. The NRC Staff feels eventual replacement will be-needed, but observes that the gaskets pose no immediate problem. Ig at 7. PNPP will monitor the Dresser Style 65 cou-plings on-its engines for any leakage and replace them, as neces-sary. Tr. 2495 (Christiansen).

173. OCRE indicated concern regarding the sufficiency of the contact between the engine base and chocks. See Staff Testimony at 54-55. Applicants provided additional information on this item at the hearing. See Tr. 2496-97. PNPP's architect / engineer es-tablished an inspection requirement of 85% surface contact for all

' heavy machinery installations. Tr. 2496 (Christiansen). If sur-face contact was less than 85%, an engineering evaluation was re-quired. Id. The PNPP foundation chock plat'es have been inspected for 85% surface contact. id. An engineering evaluation was per-formed for chock plates with less than 85% contact. Id. In all cases, the contact exceeded TDI's minimum requirements. Ig. at

. 2497. Hot and cold crankshaft deflection measurements have con-firmed that TDI's criteria have been met and that the engine is well-supported. Id.

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u -

~ ~

.. . : 174. : Thei PNPP .. engine's - wil' 1 < not? operate' beyond .185 psig ' brake

?mean effective.pressu'e r ("BMEP") without NRC Staff approval.53/

f Id.,.! at; 2266. 4 Given. favorable torsiograph test.results', engine

operation;to 224'psig BMEP will-be acceptable. Tr. 2423-2424 (Berlinger).

17'. 5 The PNPP diesel' generators will be tested prior to plant

-operation in accordance with Regulatory Cuide 1.108 (as described-in the PNPP: FSAR) and the: criteria offIEEE Std. 387-1977. Tr.

2204 -(Christiansen); Christiansen at 28-31. Testing will include

~

.a demonstration of the ability of the diesel generators to start

.and load-to LOOP /LOCA loads. Tr. 2215 (Christiansen). The range.

offloading calculations in the PNPP FSAR will be verified. .Id.

1The diesels will also be tested once'a: month and during outages.

Tr. 2205, 2255 (Christiansen).

. 176. Both the NRC Staff and PNL recommend the elimination of the additional ten fast-starts per engine =PNPP was. planning to p

f-

~ perform.54/ Tr. 2455-56 (Berlinger); Staff Ex. 5 at 7.2. PNPP will formally propose the elimination of these additional fast-

' starts to the NRCLStaff. Christiansen at '31.

f Sjb/ Preoperational' testing, however, will be conducted at' 7,000 kw rated load (224 psig'BMEP)-in accordance with Regula-

tory; Guide 1.108. See OCRE Ex. 3.

! 11/- These fast starts were in. addition to the required fast

!~ '

start testing to'be conducted in accordance with Regulatory f Guide 1.108. See~ Staff Ex. 5 at 7.1; Tr. 2456 (Perskino).

i -137-t I

i!

7 e

177.';As of the time ~of the~ hearing,..the PNPP Division'1 en-

~

fgine had run for approximately thirteen-and-one-half hours and the Division 2 engine had run for approximately seven hours. Id. at 31-32. No hardware-related incidents occurred during this opera-tion. Id.

178. Successful testing and hundreds of hours of operation have already been accumulated on DSRV-16-4 engines at other plants. Id. at 26-27. A full, preoperational test program has

.been conducted on the Comanche Peak DSRV-16-4 engines. Id. at 26.

Over 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months of operation have been logged on these engines.

Id. at 27. Over 1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months of operation have been logged on the DSRV-16-4 engines at the Catawba Plant. Id. These engines pro-vide additional assurance of the DSRV-16-4's capabilities. Id.

179. At the hearing OCRE reiterated its desire to have the 7

.PNPP engines run for 10 55/ cycles prior to plant operation.

The engines will not be run for 10 7 cycles See Tr. 2205.

prior to plant operation. Tr. 2205 (Christiansen). Testing for 7

10 cycles is only necessary where experience and/or analysis does not establish that DEMA guidelines have been met; such testing is not necessary to confirm the adequacy of the PNPP die-sels for loading to either 185 or 224 psig EMEP (7,000 kW). Tr.

2323 (Berlinger); Staff Testimony at 22.

55/ -10 7 cycles corresponds to about 750 hours0.00868 days 0.208 hours 0.00124 weeks 2.85375e-4 months at 450 rpm.

See Staff Ex. 1, Enclosure-1 at 13.

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" 180. An' Owners' Group review of'the. operational history of all

~

dieselfengines operating at nuclear sites,has. indicated that the TDI diesels-are.very reliable in starting. Tr. 2256 (Kammeyer).

Regulatory Guide 1.108 requires 99% reliability with a 50% confi-

-dence level; the results of the study indicate a confidence level of nearly 100%. Id.

181.. App. Ex. 16-1 gives the projected sequence and ultimate loading.for each engine in the event that loss of offsite power causes a forced plant shutdown. Tr. 2241 (Christiansen). In this case, the most highly-loaded PNPP engine (Division II) would have Ja maximum load of 5,634 kw which is only 82% of the engines' name-plate rating. Id.; App. Ex. 16-1.56/ It would be expected to op-erate for a maximum of 287 hours0.00332 days 0.0797 hours 4.74537e-4 weeks 1.092035e-4 months at this load. Tr. 2244 (Chris-tiansen); App. Ex. 16-1. While it is possible that additional loads could be added to the engines in the-future, this would re-quire an amendment to the PNPP FSAR (App. Ex. 16-1) which would be reviewed by the NRC Staff. Tr. 2258 (Christiansen).

182. An attachment to the performance specification for the PNPP diesel generators established PNPP quality assurance and quality control program requirements for TDI in conformance with NRC regulations. Id. at 2188-90. Periodic manufacturing audits of TDI were conducted for PNPP. Id. at 2191. The TDI quality 56/ Other loads, including the maximum load for a LOOP /LOCA (4,668 kw) are lower. Compare App. Ex. 16-1 at 8.3-76 with 8.3-81.

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F

-assurance program, as' audited by'Abplicant's, met the're'quirements of GDC 1. Ijl. at 2190. Applicants do not dispute, however, that there.were deficiencies. identified in TDI's quality assurance pro-gram. Tr. 2192 (Kammeyer). Indeed, deficiencies in TDI's quality assurance program were one of_the reasons for the formation of the TDI Diesel Generator Owners Group Program and PNPP's participation therein. Id.

183. OCRE Ex. 1 documents an audit performed in 1982 to in-spect TDI's manufacturing process for spare parts. Tr. 2236 (Christiansen). This audit resulted in a follow-up evaluation by both PNPP and its architect / engineer. Id. The subsequent evalua-tion verified the existence of complete TDI records addressing each area of concern identified in the earlier audit. Id. at 2237. The subsequent evaluation also verified that the hardware, as manufactured, was acceptable and that the TDI quality assurance program was adequate. Id. at 2267.

184. Based on PNPP's successful performance of the Owners Group revalidation effort and the testing to be performed in accordance with Owners Group and regulatory requirements, Appli-cants conclude that the PNPP TDI diesel generators will reliably perform their safety-related functions. Id. at 2257. The NRC Staff agrees that the PNPP Unit 1 TDI diesel generators will per-form reliably and that the Unit 2 diesels will do likewise, pro-vided they are also subjected to all phases of the Owners Group

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e

' ' Program'~in'the future. Staff Ex. 2; Tr. 2405-06'(Berlinger, Dingee).

185.~The Unit 2 diesels'will' complete the Owners Group Phase

'I component reviews, with components being replaced as needed.

Tr. 2483 (Berlinger). The Unit 2 diesels will also be subjected to the same Phase II revalidation (tear-down and inspection). Id.

at 2479, 2403. Inspection and maintenance requirements, as well as some component testing requirements (such as the torsiograph test) may change as additional operational experience is obtained.

Id. at 2467, 2479, 2483-84. The Unit 2 diesels will be subjected to the same preoperational testing to be performed on the Unit 1 engines, as committed to in the PNPP FSAR. Tr. 2486 (Berlinger),

Tr. 2515 (Christiansen).

186. While random component failures on the PNPP diesels are still a possibility, the Owners Group Program, as implemented at PNPP, has significantly reduced the likelihood of such an occur-rence. Tr. 2263-64 (Kammeyer). The basis for redundancy of onsite power is to preclude such a random failure from c'ausing any problem with the plant. Id. at 2263. PNPP will continue to be informed of any applicable problems with diesel generator compo-nents via reporting programs already in place (e.g., 10 C.F.R. Part 21 and Section 50.55(e) reports). Tr. 2230-31 (Kammeyer),

Christiansen at 19.

-141-

e 187.Pbior't3'lidensiny'fbr~ operation a$ove~5% of rated ther-

'~

' - ~

~

mal power, PNPP will' formally-submit to the NRC Staff, for its re-

~

, view and approval, "all- info ~rmation' (l including results of: the-torsiograph testing) identified in SER, Supp. No. 6, NUREG-0887, April-1985. Tr. 2474-76 (Berlinger).

CONCLUSIONS OF LAW The-Board has considered all of the evidence submitted by the parties for the second phase of the evidentiary hearing, concern-ing emergency planning and the TDI diesel generators. Based on the findings of fact set forth herein, which are supported by re-liable, probative and substantial evidence in the record, the Board decides all matters in controversy, except for the hydrogen contention pending before this Board, in favor of authorizing operation of the facility. The Board concludes that, as to the matters resolved herein, the Director of Nuclear Reactor Regula-tion should be authorized, upon making requisite findings with re-

.spect to matters not resolved in the Board's partial initial deci-sion, to issue licenses to operate the Perry Nuclear Power Plant to Applicants.

ORDER WHEREFORE, IT IS ORDERED

1. All issues of material fact admitted under Issue No. 1 (emergency' planning) and Issue No. 16 (TDI diesel generators) in this proceeding are found to be without merit and are dismissed.

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r 1r ~F

c. . .z , -

.g._:i).j,g.gh g..g , .). ..gg . ,.. , .' g .1 tial' decision'that will. constitute final' action of the Commission forty-five7(45)tdays'from thefdate dfrissuance unless exceptions

e. -

"are taken pursuant tcr $ 2.762 or the Commission directs that the

. record be certified to it.

3. LExceptions to this decision or designated portions thereof may be filed with the Commission, in the form required by 5 2.762(a), within ten (10)-days after service of this decision.

4. To pursue an appeal, briefs in support of a party's ob-

~jection also must be filed, within thirty-(30) days after filing the exceptions (or forty days in the case of the Staff of the

Nuclear Regulatory Commission). The brief must comply with the requirements of 9 2.762.

.5. Within thirty (30) days of the-service of the brief of the appellant-(40 days.for the Staff), parties may_ file opposing or supporting briefs that comply with the requirements of $ 2.762.

t

-143-

7:

e. :o'

~

- l Filings that do'- not" coinpl'y with"the inle ' governing ap-

' ~

'6.

peals may be stricken.

~

' Respectfully sub'mitted, SHAW, PITTMAN, POTTS & TROWBRIDGE AG

1AAC '

. E S lberg,'P.C.

ich el . Sviger l l Ros An C. Sullivan Counsel for-Applicants 1800 M Street, N.W.

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

~ Dated: May 13, 1985

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4:

.s g

^

APPENDIX A WRITTEN TESTIMONY RECEIVED INTO EVIDENCE '

DOCKETED Followih0 Witness- Transcript Page

'Baer, John Statement of Qualifications of John Baer 3047 0FFICE OF SECRETARY-

" Applicants' Direct Testimony of John ~ 00CKETggERVlf.f.

Baer on Issue No. 1 - Contention Q " 3047

" Applicants' Direct Testimony of John Baer on Issue No. 1 - Contention U" 3055

" Applicants' Direct Testimony of John Baer on Issue No. 1 - Contention Z" 3069

" Applicants' Direct Testimony of John Baer on Issue No. 1 - Contention BB" 3088

+Berlinger, Carl H.

Statement of Qualifications of Carl H. Berlinger 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

Dingee, Howard.M. Hardy, Adam J. Henrickson, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at Perry Nuclear Power Plant" 2281 Bowers, Richard R.

Statement'of Qualifications of Richard R. Bowers 2913

" Applicants' Direct Testimony of Richard R.

Bowers on Issue No. 1 - Contention M" 2914 Bush, Spencer H.

Statement of Qualifications.of Spencer H. Bush 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

Dinges, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry

. Nuclear Power Plant" 2281 A-1

,o l

i l l

Witness Transcript Page Christiansen,-Edward C.

Statement of Qualifications of Edward C. Christiansen 2179

" Applicants' Direct Testimony of Edward C.

Christiansen on Issue No. 16" 2179

-Cole, Kenneth B.

Statement of Qualifications of Kenneth B. Cole 2834

-"Applicants' Direct Testimony of Kenneth B.

Cole on Issue No. 1 - Contention M" 2835 Dinnes, David A.

Statement of Qualifications of David A. Dingee 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

Dingee, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry Nuclear Power Plant" 2281 Hankins, Deborah~

Statement of Qualifications of Deborah Hankins 3158

" Rebuttal Testimony on NUREG/CK-2239" 3158 Hardy, Howard M.

Statement of Qualifications of Howard M. Hardy 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

'Dingee, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue No. 16 Concerning TDI Emergency Diesel Generators at the Perry Nuclear Power Plant" 2281 Henrickson, Adam J. .

Statement of Qualifications of Adam J. Henricksen 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

[ Dingee, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry l Nuclear Power Plant" 2281 A-2 l

<s_ .

-l

'l i

A Witness Transcript Page '

Hulbert, Daniel D.

Statement of Qualifications of Daniel D. Hulbert 2964

'" Applicants' Direct Testimony of Daniel D.

-Hulbert on Issue No. 1 Contention J" 2965

" Applicants', Direct Testimony of Daniel D.

Hulbert'on-Issue No. 1 - Contention CC" 3091 Kammeyer,lJohn C.

Statement ~of Qualifications'of John C.'Kamseyer 2179

" Applicants' Direct Testimony of John C.

Kammeyer on/ Issue No. 16" 2179 Kirkwood, B. J Statement of Qualifications of B. J. Kirkwood 2281

" Joint. Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David A.

Dingee, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry Nuclear Power Plant" 2281.

Linnemann, Roger E.

Statement of Qualifications of Roger E. Linnemann 2978

" Applicants' Direct Testimony of Roger E.

Linnemann on Issue No. 1 - Contention P" 2980 McCandless, Scott T.

Statement of-Qualifications of Scott T. McCandless 2790

" Applicants' Direct Testimony of Scott T.

McCandless on Issue No. 1 - Contention A" 2791 McTrusty, Robert L.

" Testimony _of Dr. Robert L. McTrusty, Chairman, Ashtabula County Medical Center Disaster Committee" 3149 Perrotti, Donald J.

Statement of Qualifications of Donald J. Perrotti 3111 1

i A-3

g-1 Witness Transcript Page

" Testimony of Donald J. Perrotti Regarding Emergency Plan Issues" 3111 Persinko, Drew Statement of-Qualifications of Drew Persinko 2281

" Joint Testimony of Carl H. Berlinger, Drew Persinko, Spencer H. Bush, David-A.

Dingee, Howard M. Hardy, Adam J. Henricksen, and B. J. Kirkwood on Issue 16 Concerning TDI Emergency Diesel Generators at the Perry Nuclear Power Plant" 2281 Shapiro, Robert O.

Statement of Qualifications of Robert O. Shapiro 3111

" Testimony of Robert O. Shapiro, Federal

-Emergency Management Agency Regarding Emergency Planning Contentions A. M P, Q, U, Z, BB" 3111 Sternglass, Ernest J.1/

Statement of Qualifications of Ernest J. Sternglass 2566

" Testimony by Dr. Ernest J.

Sternglass" 2566 Wood, III, Charles D.

Statement of Qualifications of Charles D. Wood, III 2179

" Applicants' Direct Testimony of Charles D.

Wood, III on Issue No. 16" 2179 1/ The Board ordered the words " Summary of," which appear in the original, stricken from the title of Dr. Sternglass' testimony. Tr. 2564.

A-4

.. . . . -. . _ _= . _ . , __. . _ _ . _ _ . . _ . _ . ._ _

r

'r ORAL TESTIMONY WITHOLIT WRITTEN TESTIMONY Introduced on Witness. Transcript Pane 1

. , - Wills,-John M. 3200

[- (Witness for Applicants) e i -

7 I

r 4

}

I-4 4

1 1

4

, A-5

D' 2 i' APPEllDIX B EXHIBITS IDENTIFIED AT' ADMITTED AT FOLLOWING EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT ItuMBER_ DESCRIPTION PAGE PAGE PACE App. Ex. 1-1 Advisory Committee 2599 2602 2602 on the Biological Effects of Ionizing Radiations, "The Effects on Populations of Exposure to Low Levels of lonizing Radiation," Nov. 1972, pp. 177-79 App. Ex. 1-2 Committee on the Bio- 2608 2608 2608 logical Effects of lonizing Radiations, "The Effects on Pop-

ulations of Exposure to Low Levels of lonizing Radiation: 1980,"

pp. 463-64 App. Ex. 1-3 EPA Final Environmental 2681 2611 2611 Sta tement "Envi ronmenta l Radiation Protection Requirements for Normal Operations of Activities in the Uranium Fuel Cycle,"

November 1, 1976, pp. 186-88 App. Ex. 1-4 EPA Letter f rom D. M. 2618 2618 2618.

Costle to C. J. Dodd, dated August 9, 1978 re Strontium-90 Report by Dr. Sternglass App. Ex. 1-5 Lette r f rom W. D. Rowe to 2620 2620 ~

2620 to J. C. Cleveland, dated August 2, l978 re Report on QQ n'}

Mortality Changes Around %c Nuclear Facilities in mm : o Connecticut, authored by gh$ g C8 g

Dr. Sternglass wo , zy

$#gn M G bM zgm a 2c; a.

5>

. bl 4

B-1

IDENTIFIED AT

ADMITTED AT- FOLLOWING EXHIBIT TRANSCRIPT TRANSCRIPT TRAleSCRIPT NUMSER DESCRIPTION PAGE PAGE PAGE App. Ex. 1-6 EPA Le tte r f rom W. A. Mi l l s 2622 2622 2622 to B. Lindell, dated februa ry 7, 1980 re EPA comments on statements made by Dr. Sternglass App. Ex. I-7 Newsletter Supplement - 2625 2625 2625 April 15, 1970 - Committee Statement - Committee on Envi ronmenta i Ha za rds, American Academy of Pediatrics App. Ex. 1-8 Statement by Dr. Dade W. 2627 2627 2627 Moeller, President, Health Physics Society, to South Carolina Legislative Investi-gating Committee, September 30, 1971 App. Ex. 1-9 NRC Letter from J. M. Hendrie 2628 2628 2628 to C. J. Dodd dated January 18, 1978, re NRC's evaluation of Strontium-90 Report by Dr. Sternglass App. Ex. 1-10 Letter from H. R. Denton 2629 2629 2629 to C. J. Dodd dated ,

July 27, 1978, re review of Dr. Sternglass' allegation concerning levels of Strontiust and Cesium in the Connecticut environment App.. Ex. Testimony by the Document. WITHDRAWN, 2631 (Unnumbe red ) Representatives of the Not Marked Bureau of Radiological in Record, Health of the Public Egg Tr. 2630 Hea l th Se rv ice ent i t led, "A Critical Review of Infant Mortality and Nuc lea r Powe r Cene ra t ion by E. J. Ste rng la ss" B-2

c

^,

i IDENTIFIED AT ADMITTED AT FOLLOWING EXHIBIT TRAllSCRIPT TRANSCRIPT TRANSCRIPT NUMBER DESCRIPTION PAGE PAGE PAGE App. Ex. NRC Letter from L. Cossick . Document WITHDRAWN, 2633

( unnumbe red ) to T. Cochran dated Not Marked December 17, 1979, in Record, responding to Dr. jeg Tr. 263 8-32 Sternglass' allegations of rise in infant mortalities following Three Mile Island accident -

App. Ex. 16-1 Table 8.3-8 f rom PNPP FSAR, 2242 2243 2243

" Connected, Automatic and Manual Loading and Unloading of Engineered Safety Evaluations Features Switchgear" Staf f Ex. 1 Memo from D. Eisenhut 2284 2284 2284 to Commissioners dated August 29, 1984, re SER on TDI Owners Group Program Plan and San Onofre C ra nksha f t Indications; "SER on TDI Diesel Generator Owners Group Program Plan" Sta ff Ex. 2 "SER on TDI Diesel 2286 2286 2286 Generators, Perry Nuclear Power Plant, Unit I;"

Memo f rom C. H.

Berlinger to B. J.

Youngblood, enclosing SER, dated February 25, 1985 Staff Ex. 3 " Post-Test Examination 2287 2287 2288 of the TDI Emergency Diesel Generator 103 Pistons and Related Components at Shoreham Nuclear Power Station" B-3

- c ;

IDENTIFIED AT ADMITTED AT FOLLOWING EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT NUMBER DESCR1PTION PAGE PAGE PAGE Starr Ex. 4 Copy of a slide presen- 2290 2290 2290 tation, " Summary of Conclusions and Recommendations on Resolution of Known Probless in 101 Diesel Generator Components (Phase i of Owners Group Prog ram), Pacific Northwest Labora to ry" Staff Ex. 5 "A Review of the 2292 2292 2292 Operability and Reliability of TDI Diesel Generators at Perry Nuclear Power Plant, Unit I," - PNL-5418, dated February 1985 Starr Ex. 6 "SER Related to Operation 2294 2294 2294 of Perry Nuclear Power Plant, Units I and 2 " dated Februa ry 1984 - NUREG-0887, Supp. No. 4 Sta f f Ex. 7 "SER Related to Operation 2296 2296 2296 of Perry Nuclea r Power Plant, Un i t s I a nd 2,"

dated February 1985 -

NUREG-0887, Supp. No. 5 FEMA Ex. I FEMA Interim Report on 31I0 3811 3111 Orrsite Radiological Emergency Planning for the Pe rry Nuc lea r Powe r Station, dated January 10, 1984 FEMA Ex. 2 Exercise Report from the 3810 3111 311I November 28, 1984 exercise for the Perry Nuclear Power Plant ,

FEMA Ex. 3 Regional Assestance 3110 3118 3111 Committee Consensus Review, November 20, 1984 Sunflower Slide of Upstate,Meu Vork 2586 REJECTED, 2588 -i '

Ex. I Infant Mortality ute , ,

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IDENTIFIED AT' ADMITTED AT c FOLLOWING :}

EXHIBIT TRANSCRIPT ' TRANSCRIPT # TRANSCRIPT

~d PAGE NUMBER DESCRIPTION # PACE PAGE s a r' cm

'r, . Sunflowe r Silde er Ohio snrant' ' '

2586 - -

REJECTED, 2588 Ex. 2 Mortality Rate Sunflower Slide of Monthly infant 2587 REJECTED, 2588 Ex. 3 Mortality Rate f; f elative

~#' to the U.S. ,e Sunflower Slide or Maryland anrant 4587 REJECTED, 2588 Ex. 4 Mortality Rate forN979 ,

~

and 1980 Sunflowe r Slide of Strontium-90 Levels 2587 REJECTED, 2588 Ex. 5 -

Sunflowe r Slide or Infant Mortality 2587 REJECTED, 2588 -

y . '3 Rates for Rhode Island and Ex. 6

/ Icew Hampshire Sunflowe r Graph of Mortality Rate 2739 2739- 2739 Ex. 7 in the U.S. for Infants 0- 1 y r.

Sunflowe r Dra f t Graph of U.S. Infant 2739 2739 2739 Ex. 8 Mo rta l i ty Ra te pe r 1000 live births (0-1 year)

Sunflower Letter from D. B. Wedge 2807 3152 3152 Ex. 9 to J. Dugan, dated Ma rch 26, 1984, re Comments on Time Evacuation Study Sunflower Article from Reacts. Oak 3021 REJECTED, 3I53 Ex. 111/ Ridge Associated Universities, re the safe handling or radioactive cadavers Sunriower Ohio Disaster Services 30622/ 3154 3154 Ex. 12 Agency Radiological j T ra ining Ma nua l, p. 7-10 l

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i 1/ Exhibit No.10 erroneously omitted from numbering sequence.

2/ Exhibit Iso.12 erroneously referred to Exhibit No. 10, Tr. 3062.

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'r w i- -

IDENTIFIED AT ADMITTED AT FOLLOWING EXHi81T TRANSCRIPT . TRANSCRIPT TRANSCRIPT NUMBER DESCRIPTION PAGE PAGE PAGE 9.,-

Sunflower EPA Manual of Protective Document 3155' 3155 ,

Ex. 13 Action Guides and 800t Marked Protective Actions for in Record Nuclear incidents, '. ' s September 1975, p. 1.29 Sunflower Appendix 10 of Asistabula Document 3856 3156 Ex. 14 County Plan Not Marked in Record OCRE.Ex. I- Gilbert / Commonwealth - 2190 2191 2191 Ap ri l 12, 1982 Letter of.

Transmittal and Report '

on Manufacturing Audit

Conducted at TDI on r February 23-25, 1982 w OCRE Ex. 2 Executive Summary Summarizing 2199 2200 2891,s2200 Status of Owners Group; l

" Proposal for Closure of TDI l Owners Group," from the s Executive Committee Meeting of January 9, 1985; Memo to File dated i January 10, 1985 re Owners Group Executive Committee ^

Meeting Minutes, January 9, ,

1985 OCRE Ex. 3 Letter f rom 8. J. Youngblood 2203 2203 2203 to M. Edelman dated Ma rch 25, 1985, re confirmation of TDI Diesel Generator I .1-Licensing Tests for Perry Nuclear Power

, Plant OCRE Ex' 4 " Applicants' Answers to 2207 2207 2207 OCRE 11th Set of Interroga-tories to Applicants," dated Ma rch 8, 1984 - Responses to Interrogatories 18-10 and 11-11 s OCRE Ex. 5 Memo from C. L. Ray, 2212 2282 2212 Jr. to owners Group re July 18, 1984 Meeting between NRC/PNL/0wners Group (undated) 8-6

l I

IDENTIFIED AT ADMITTED AT FOLLOWileG ;

EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT l NUM8ER DESCRIPTION PACE PAGE PAGE I 1

OCRE Ex. 4 Letter from B. K. Crimes 2214 2214 2284 to M. Edelman dated Ma rch 26, 1985, re Integrated Design inspection 50-440/84-29, Supplement I, with Portion of Report l Addressing Unresolved item )

US.2-1, Motor Accelerating i

f Time OCRE Ex. 7 " Metallurgical Evaluation 2226 REJECTED, 2235

- of Diesel Generator Cylinder Head Valve Seat Cracks at Grand Guir Nuclear Station, Unit 1," dated June 1984 OCRE Ex. 8 Letter from Boyer to NRC 2228 2229

2229 Director of Orrice or Inspection and Enforce-ment, dated Ma rch 18, 1985 OCRE Ex. 9 Copy of the deposition of 2311 REJECTED, 2313 William Foster and Cari j Berlinger from the Shoreham proceeding, dated May 22, 1984 OCRE Ex. 10 Board Notification 84-101; 2336 REJECTED, 2338 and Excerpt or Report of Investigation into the Shoreham crankshaf t failure conducted by Franklin Research Center OCRE Ex. Il Cambit Newspaper article, 2397 REJ ECTED, 2397 no date supplied B-7

A May 13, 1985.

UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC Before the Atomic Safety and Licensing Board TS My 15 All:07 In the Matter of )

0FricE OF SECfttTApy

)

THE CLEVELAND ELECTRIC 00CKETING & SERvlu'

) Docket Nos. 50-440 BRANCH ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Appli-cants' Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Initial Decision (Emergency Planning and TDI Diesel Generators)" were served by deposit in the United States Mail, First Class, postage prepaid, this 13th day of May 1985, to all those on the attached Service List.

/1b - L/ (I JA T SI BERG,'P.C.

Dated: May 13, 1985

)

6 I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND-ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET__ _A_L. ) 50-441 (Perry Nuclear Power Plant, )

Units 1 and 2) )

SERVICE LIST James P. Gleason, Chairman Atomic Safety and Licensing 513.Gilmoure Drive Appeal Board Panel Silver Spring,. Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Glenn O. Bright Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Ms. Sue Hiatt Atomic Safety and Licensing OCRE. Interim Representative Appeal Board 8275 Munson Avenue

-U.S. Nuclear Regulatory Commission Mentor, Ohio 44060 Washington, D.C. 20555 Dr. W. Reed Johnson Terry Lodge, Esquire

-Atomic Safety and Licensing 618 N. Michigan Street, Suite 105

-Appeal Board Toledo, Ohio 44060 U.S. Nuclear Regulatory Commission.

Washington, D.C. 20555 Gary J. Edles, Esquire . Donald T. Ezzone, Esquire Atomic Safety and Licensing. Assistant Prosecuting Attorney Appeal Board .

Lake County Administration Center U.S. Nuclear Regulatory Commission 105 Center Street Washington, D.C. 20555 Painesville, Ohio 44077 Atomic Safety and Licensing John G. Cardinal, Esquire Board Panel Prosecuting Attorney U.S.. Nuclear Regulatory Commission .Ashtabula County. Courthouse Washington, D.C. 20555 Jefferson, Ohio 44047

ML20117L250

Text

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