ML20128B657

Proposed Findings of Fact & Conclusions of Law in Form of Partial Initial Decision for Issue 16 Re Tdi Diesel Generators.Ol Applications Should Be Denied.Certificate of Svc Encl

ML20128B657
Person / Time
Site:	Perry
Issue date:	05/22/1985
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
References
CON-#285-131 OL, NUDOCS 8505280005
Download: ML20128B657 (66)

Text

'

lPf j'pl o- ,

2*

e ,

r:o y 22, 1985 DOCKETED USNRC UNITED STATE 5 0F AMERICA NUCLEAR REGULATORY Cot!NISSION 15 MY 24 m0:26 Bercre the ceomte sareey ano Licenssng so6FdCE OF SECRt'iA.: ;

7ssenETING & Sgpyg ORANCH In the Motter or >

)

THE CLEVELAND ELECTRIC ) Docket Hos. 50-440 OL ILLUMINATING CO. ET AL. ) 50-441 OL

)

(Perry Nuclear Power Pione, )

Units 1 ond 2) )

OCRE'S PROPOSED FIfiDING5 0F FACT AND CollCLUSIONS OF LAW If1 THE FORM OF A PARTIAL If1ITIAL DECISION (ISSUE N16. TDI DIESEL GENERATORS)

Susan L. Hiatt OCRE Representatzve 8505280005 850522 PDR G

ADOCK 05000440 PDR g$

\

t _

f

.c.

. c' TABLE OF CONTENTS .

Page I. OPINION ............................................ 1 R. HISTORY OF THE CASE .............................. 1 B. BACKGROUND OF ISSUE N16 .......................... 6 C. APPLICABLE STANDARDS ............................ 11 D. THE OUNERS GROUP PROGRAM ........................ 13

1. The Owners Group .............................. 13

2. Elements of the Owners Group Program . . . . . . . . . . _16

-(o). Phase I ................................... 16

• (b). Phase II .................................. 16

'(c). Engine Testing and Inspection . . . . . . . .- . . . . . 17 (d). Maintenance and Surveillance . . . . . . . . . . . . . . 18

3. The Stoff's Review ............................ 20

4. Conclusions os to Adequacy or.the Owners Group Program

............................................. con-E. PHASE I C0tiPONENTS .............................. 24

1. Componenes Not contested by OCRE . . . . . . . . . . . . . . 24

2. Contested. Components .......................... 25 (a). Engine Bose and Beoring Cops . . . . . . . . . . . . . . 25 (b). Turboenorsers ............................. 26 (c). Cronkshort ................................ 27 (d). Cylinder Block and Liner .................. 29 i F. PHASE II COMPONENTS ............................. 31

1. Dresser Couplings ............................. 31

2. Foundation .................................... 32 t--

2

~s: .

.. ;p' , l

- s - ;,: ,

...A .

c ': . . ..

=II'.' FINDINGS OF FACT ~................................. 32

=III.--CONCLUSIONS-0F L'AW............................... 56 r_

- 1 0 ; ! O R D E R . . . . . . . . . . . . ~. .~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 7 a

7 App'endixLA, Written: Testimony Received into Evidence ,

4

. Appendix B ,.-. Exhibits-f (

6 5

4 e

r- ,

s 3

4 d

}

' . . . g M

i e

..F. &

7 4

y

' I}

b 4 s .

[ y n

}

+

t

't 4

2 4

A

' A h

I i

.O W lh i

s i

_-,.,J...1,...aJ...-...1. ..2--..,.-- ,. ., . _ . . . , , - . - - . _ - . - - - , , _ - - - - - ...-. -- . - -- - .. -. -

9.-

May 22. 1985 UNITED STATE 5 0F AMERICA NUCLEAR REGULATORY COMMISSION Beroce the Atomic Sofety'and Licensing Board In.the Motter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 OL ILLUMINATING CO. ET AL. ) 50-441 OL

)

(Perry Nuclear Power Plant. )

Units 1'ond 2) )

OCRE'S PROPOSED FINDINGS OF FACT AND CONCLUSION 5' 0F LAW IN THE FORM OF A PARTIAL INITIAL DECISION

-(ISSUE W16. TDI DIESEL GENERATORS)

Pursuant to 10 CFR 2. 754 (o) (2) . Intervenor Ohio Citi: ens for, Responsible Energy ("0CRE') hereby submits in the form of a partial-initial decision its proposed'rstidings of fact and conclusions of-low relating to Issue M16, on TDI diesel

-generators, in this proceeding. The proposed findings of fact one conclusions o'f low follow the form prescribed by the Atomic-Safety and Licensing Board in its April 18, 1985 Memorandum and Order (Proposed Findings and Conclusions).

I. OPINION A. HISTORY OF THE CASE This is the second partial initial decision in this

' contested proceeding on the application for operating licenses for the Perry Nuclear Power Pland ('PNPP'). Because the Licensing Board's first portici initial decision. LBP-83-77, 18

-NRC 1365' (1983). did not include o detailed description of the

<v boexground or this proceeding, the history of the cose is outlined herein.

the oper_otion or two boili_ng ,,wo t.e r

_ _. , _. T h e , a p p l i c.a ,t i o n . i s r. o r..

~. . . . . .

-reactors, Units 1 and 2, at the Perry site in Lake County, Ohio,

. located opproximately 35 miles northeast of Cleveland on Lake Erie.

'The Applicants, The-Clevelona Electric Illuminating Co.

Pennsylvania Pouer

('CEI'). Duquesne Light Co., Ohio Edison Co.,

Co., and The Toledo Edison Co., filed their operating license On February oppli,otion c for PNPP with the NRC on June 26, 1988.

13, 1981, the NRC published a Federal Register Notice or

' Receipt or Application for Facility Operating Licenses.

Consideration or Issuance of Facility Operating Licenses, and Opportunity-For Hearing' (46 Fed. Reg. 12372).

This notice provided on opportunity for any person whose interest might be ofrected by the proceeding to request a hearing and to rile o petition for leove to intervene, Several filed petitions in response to the organi:otionsandl individuals

-Federal Register Notice.

By Order doted April 9, 1981, the Board mode initial .

determinations concerning party status and scheduled a special preheoring conference pursuant to 10 CFR 2.751a. The Board convened'the special preheoring conference in Painesville, Ohio on June 2-3, 1981, and thereorter issued a special preheoring conference order on party status, contentions, and discovery.

See'5pecial Preheoring Conference Memorandum and Order Concerning Party Status. Motions to Dismiss and to stay, ene Admissibility of Contentions, and the Adoption or Special l Discovery-Procedures, LBP-81-24, 14 NRC 175 (1981).

I

- - . . -- - - - ~

, ,,_m, _.

Party status was granted to Intervenors Ohio Citi: ens for ,

i Responsible Energy ('OCRE*), Tod J. Kenney, and a number or ,

c other individuals and groups consolidated as Sunflower Alliance,

-Inc. et al. ('Sunriewer'). LBP-81-24 at 177. . Mr. Kenney'was -(

r

'~1oter' dismissed as o party. See April 8, 1982 Memorandum and 13

-Order ~(Concerning Motion to Dismiss). The Lake Couner Board 1sr Commissioners and the Loke County Disaster Services Agency were admitted os non-party particaponts pursuant to 10 CFR 2.715 (c) .

?

. Subsequently, the Ashtabulo County Commissioners and Ashtabulo .!

i County Disaster Services Agency petitioned for and were granted }

odmission as non-porty participonts under Port 2.715(c).

See Memorandum and Order (Concerning the Status or Ashtabula County and Objections to the Special Preheoring Conference order), LBP-81-35, 14 NRC 682 (1981).

The Board in its special preheoring conference order s

I admitted seven issues to the proceeding. LBP-81-24 at 232-33. ,

In addition, nine l' ate-riled contentions have been admitted in i i the course of the proceeding.

Of the sixteen issues admitted, thrL~ have been' dismissed pursuont to Commission rulemoking 'or policy statement. Those ,

issues are Issue W6 (automatic standby liquid control system), c Memorandum and Order (Denying Motion for Summary Disposition on OCRE Issue No. 6 and Dismissing the Contention), LBP-84-40, 20 HRC 1181 (1984)r Issue No. 10 (psychological stress), Memorancum and Order (Concerning Psychol 09ical Stress Contention), LBP 53A, 16 NRC 208 (1982); Issue No. 2 (financial qualifications),

April 28, 1982 Memorondum and Order (Concerning Motion to

..b

-4

, Dismiss Financial Qualificacions Contention).

Nine other. Issues have been summarily disposed of as the result of motions by Applicant: and the NRC Staff. These issues are Issue.t03 15 (steam erosion), March 13, 1985 Memorandum and Order (Motions) and April 9, 1985 Memorandum and Order (Moeions i for Summary Disposition of Issues 1, 15, and 16) (provsding explanation for earlier order); Issue No. 14 (in-core

.thermocouples), Februory 27, 1985 Memorandum.ond Order (Motion for Summary' Disposition on In-Core Thermocouples. Issue 14)s Issue No. I'3 (turbine missiles), LBP-83-46, 18 NRC 218 (1983);

Issue No. 9 (polymer degradorion). Tr. 827-28 (Preheorzns Telepnene Conference or Hoy 9, 1983) and Memorandum"ond Order (Polymer Degradotton:

Summary Disposition), LEP-83-18, 17 NRC 501 (1983); Issues No. 4

-(emergency core cooling system), No. 11 (environmental impact statement cost-benefit colonce), and No. 12 (economic costs of serious occidents), Hemorandum and Order (Concerning Summary

?

Disposition), LBP-82-119, 16 NRC 2063'(1982): Issues No. 5 (scrom discharge volume piping) and No. 7 (Asiatic clams),

~ Memorandum and Order (Concerning summary Disposttion:

Quality Assurance, Corbiculo and Serom Dischorse Volume contentions), LBP-82-114, 16 NRC 1909 (1982).

Issue No. 3 (quality assurance) Was the subject of the first phGse of the evidentiary hearing held May 24-27, 1983 in Fotnesville'. On December 2, 1983, the Board issued a Partial snitial decision which concluded in favor of Applicants.

Portial Initial Decision (ouclity Assurance contention), LBP-S3-

. -S-i 77, 18 NRC 1365 (1983). That portial initici decision was offirmed by the Appeal Board in ALAB-802, 21 NRC ___ (Horch 26, .

1985).

.The second phase of the hearing concerned Issues No. 1 (emergency planning) and No. 16 (TDI diesel generators). Direct testimony wos 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 CFR 0,715(o) during on evening session on April 11, 1985, and also granted on unscheduled

. limited appearance on April 12. 1985. Tr. 2907-11. This * ,

partial initial decision concerns only Issue No. 16.

The third phase'of the evidentiary hearing, which was held on Apri1J30 through May 3, 1985, oddressed Issue No. 8 (hydrogen control) and will be'the subject or o subsequent portial initial

. decision.

The decisional. record of the proceeding on Issue No. 16 consists of the tes'timony and exhibits filed by the porties, and tne other evidence contained in the transcripts *of the heoring.

Appendix A to this decision identifies the location of Written testimony in the transcript. Appendix B lists the exhibits C

identified, indicates the Board's ruling on any offer of an extibit into evidence, and identifies the location of admitted

. exhibits in the transcript.

In preporing our decision, we reviewed and considered the entirs record and the Froposed findings of fact and conclusions of low submitted by the porties. Those proposed findings and conclusions.that are not incorporated directly or by inference m.

2.

q

. + . -

'in this partial - initial decision are rejected as meing

+ .

unsupported by-the record'or the cose or as being unnecessory to the'icadering or this'decasion.

-This Board's Jurisdiction is limited to o determination or

+

findings of roct and conclusions of low on matters put into controversy by the partie's to the proceeding or round by the

\,.

~

Board to involve.o serious sorety, environmental, or common defense and security question. 10 CFR 2.7600 The Board has made no-such additional determinations in this cose.

6..' BACKGROUND OF I55UE n16 Issue No. 16 concerns the ability or ene four Transomersco Delovol, Inc. ("TDI') diesel 9enerators in place at PNPP (two for eacn Unit) to reliably generate emergency onsite power.

Intervenors Sunflower and OCRE filed separate diesel generator contentions. Both Applicants and the Starr opposed admission or the contentions. Neither Sunriower's nor OCRE's original contention concerning the PNPP diesel generators was admitted by the Board. See LBP-81-24 at 222-24.

OCRE subsequently filed a motion to resubmit its contention on the diesel generators. This motion was opposed by Applicants and the Starr. The 5 torr subsequently re-examined its position, in light of new information, and later supported the admission of OCRE's late-riled diesel generator contention.

The contention was admitted in this proceeding on December 23, 1983, with OCRE os the lead intervenor. The Board simplified the contention resubmitted by OCRE. See Nemorandum

5 ond order (New Contention on Diesel Generators), LBP-83-80, 18 HRC 1404 (1983). .As admitted by the Board, Issue M16 states:

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

The Board's basis for odmitting Issue M16 was.the number of deficiencies reported vio Deficiency Analysis Reports ('DARs')

on the PNPP TDI diesel generators which raised design and manufacturing concerns, and crocks in the crankshorts in the TDI diesel generators installed at the Shoreham Nuclear Pouer Station-(=Shoreham*). LBP-83-80 ot 1405-07.

c Briefs on NRC regulations and guidance opplicable to Issue N16;were. submitted by OCRE, the Stoff, and Applicants, pursuont to the Board's directive. Reply briefs were thereafter filed by 0CRE and. Applicants.

Discovery on this issue closed on June 1, 1984. It included i

.three sets of interrogatories to the Applicants by OCRE ond one set or interrogatories and request for production of documents I

to OCRE from Applicants. On January 7, 1985, OCRE riled a motion'to reopen discovery on Issue M16 olong with another set of interrogator.es to Appliconts. Applicants voluntarily responded to the new 5et of interrogatories and produced the

i. moJority of the documents requested.

1 On February 5 ,' 1985, Applicants filed a motion for summary disposition or Issue M16. Applicants' motion was supported by

~

the Storr and opposed by OCRE.

Arter considering the rilings or the parties, the Boord denied Appliconts' summary disposition y motion. See March 13, 1985 flemorandum and Order and April 9, 1985 Memorondum and order. The Board indicated that its r -

'-r - . . . . .

, _g-decision was Scverned by the technical complexity of the issus.

On February 11, 1985, OCRE filed a motion to have Hr. George l

Dennis Eley, on individual who had testified on behalf of j

intervenors'in the Shoreham proceedings on TDI diesel

(

generators, oppointed'os a Board witness in this proceeding.

l. .0CRE-Justified its request by citing its inability to pay Mr.

l Eley's fees and expenses. After considering the opposing i filings'of the other porties, the Board denied this motion. See

_Horch 13, 1985 Memorondum and Order and Memorandum and Order l

(Motion for-Appointment'of Board Witnesses) (March 26, 1985)

(explaining the Board's decision). Therein we decided that the j need for o board witness could not be established prior to

-development of' O l'

i decisional record on the issue. OCRE subsequently filed a f-motion for directed certification of the Board's decision on i.

March 16, *?S5.

This motion was opposed my both Applicants and the Staf.f. The Appeal Board refused to delay the evidentiary i

nearing on' Issue M16, os requested by OCRE (see April 2, 1985 .

t l Order), and subsequent;y denied OCRE's motion (ALAB-805, 21 NRC I

...(April 10, 1985)), o9 Peeing'with'Stoff and Applicants that i

the standard for interlocutory review had not been met. q After. reviewing the record, we believe that the testimony of 0 board witness such as Mr. Eley would have been useful, particularly on the complex components such as the cylinder ,

block and cronkshaft. However, enough doubt hos been raised as

'to~the adequacy.of these and other components through OCRE's cross-examinotion that we cae denying the operating license, thus. rendering the boors witaess question moot.

-9_

Prefiled written testtmony on the diesel generator issue ws submitted by Applicants and the starr. OCRE riled no testimony.

OCRE riled o motion to strike portions or Applicants' and the ,

s cor r 's restimony on April 1, 1985. This motion was subsequently denied, as to Applicants (Tr. 2170), and withdrawn, as to the Starr (Tr. 2 81).

Applicants' witnesses at the evidentiary hearing on Issue

1. 16 were Edward C. Christiansen, John C. Kommeyer, and Chatles l_j D. Wood, III. Mr. Christionsen is the senior Design Engineer at PNPP responsible for the Electrical Unit or the Nuclear ,

Construction Engineersng section. His responsibilities include as the coordinotion or engineeriTg and licensing activities involved With the diesel generators and associated stondby power rocilietes at FNPP. Mr. Christionsen octed as CEI's technical representative to the TDI Diesel Generator Owners Group (*0wners Group *).

Mr. Kommeyer is on employee or Stone & Webster Engineering 1

Corporation who ii Currently acting os the Assistant Head or the site Engineering Orrice at Shoreham. Over the lost 5 years his responsibilities at Shoreham have provided him with ramiliarity 1

with the problems and technical tssues involving TDI diesel generators. Mr. Kommeyer served as the Owners Group Program -

Manager and had the overo11 responsibility for implementation or l

the Owners Group Debtsn Review / Quality Revolidation Program for TDI diesels in nuclear service.

Mr. Wood is the Vice President or the Engines. Emissions, and Vehzele Research Division or Southwest Research Instieure

(*SWRI*) which was employed by Applicants to independently

-t o -

... review the owners-Group onalyses or. 16 engine components

-exhibiting potentially generic problems (Phase I of the Owners Group Progrom). Mr. Wood hos nearly 30 years or engineering experience With extensive Work involving dirrerent types or diesel _ engines. Mr. Wood is the author or numerous publications concerning diesel engines and holds a number of potents.

The Stoff's witnesses were Dr. Cori H. Berlinger, Drew Persinko, Dr. David A. Dingee, Howard M. HordY, Adam J.

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

Berlinger is a member of the NRC Storr, currently acting as the

~

NRC~TDI Diesel. Generator Project Group Manager. Dr. Berlinger holds 0 PhD in mechonical engineering and has nearly 12 years experience with the NRC in the Systems Integration, Licensing, ond Operating Reactors Divisions.

Mr. Persinko is also o member or the NRC Starr employed as on Integrated Assessment Project Manager in the Licensing Division. Mr. Persinko is a member or the'TDI Diesel Generator i

As'such,_he has been responsible for Stoff Project Group. .

review of the TDI-diesel generators at PNPP and-Comanche Peck,

'and has assi5ted in the review 5 at a number or other plants.

Dr. Dingee is employed by Pacific northwest Laboratory u

i

• P N L ) and is currently serving as Deputy Project Manager on the Assessment or Diesel Engine Reliability /0Perobility project being conducted for the NRC Storr. Dr. Dingee holds o PhD in physicE.

Nessrs. Hardy, Henriksen, Bush, and Kirkwood are all employed _05 engineering consultants to PNL. Mr. Hardy is a

' specialist An engine dynamic Vibration onolyses and hos worked

. - \ \-

~~

w~ + _ ___

exeensively uith medium to large diesel and gas engines.

Nessrs. Henriksen and Kirkuood have o considerable amount of experience in diesel engine opplications and contributed

\

extensively to the technical evoluotion of the PNPP engines' reliability / operability, Dr. Bush' holds o PhD in metallurgy, is o consultant'to the Advisory Committee on Reactor Sofeguards, onc nos extensive experience in materials science.

OCRE presented no' direct testimony, but cross-examined both Applicants' and the stoff's uitnesses, C. APPLICABLE STANDARDS At the outset, it ss necessory to establith the standards uhich govern our determination of this issue, Of the Commission's regulations, General Design Criteria 1 and 17 of Appendix A to 10 CFR Port 50 ore applicable, GDC 1 requires that systems, structures, and components important.to safety be designed. Fabricated, erected, and tested to quality standor,ds commensurate uith the importance of the

- sofety function to be performed.

GDC 17 requires or, onsite electric pouer system to nove sufficient independencs, redundon0y, and testability to perform its'sofety function assuming a single failure, The safety function as tc assure that (1) specified acceptable fuel design limits one design conditions of the reactor coolant pressure bouncory are not exceedec a o result of anticipated operational occurrences and (2) the core is cooled and contoinment integrity

- and.other vital functions are maintained in the event of postulated occidents, We find that the PNPP-specific standard for determining

9 Whether the' diesel generators meet these regulations is the performance specification, SP-562-4549-00, and its attachmene specification SP-706-4549-00. Findings 4 and 5. This specification is the standard which the diesel manufacturers which submitted bids to CEI had to meet, and the standard by which one of the bidders Wos rejected. 'Christionsen, Tr. 2186.

We believe_,. that the performance specification is as applicable to the TDI diesels now installed as it was to them in the bidding process. The specification sets forth certain criterio which we will use in our evoluotion of engine components. The specification requires that the' diesel generators te of high availability and of proven reliability. Finding 4. The specification also imposes quality assurance requirements on TDI to ensure compliance with the Commission's quality ossurance regulations. Finding 5.

It-is beyond dispute that the numerous failures and problems with TDI diesels hos demonstrated their lock of reliability.

Finding 12. See also Long Island Lighting co. (Shoreham Nuclear Power storion). CLI-84-8, 19 NRC 1154 (1984) (statsne that the Shoreham facility was not in compliance with CDC 17).

There is ample evidence.that GDC 1 hos been violated as well. See, e.g.. Stoff Ex. 1 at li Berlinger, Tr. 2313-14.

OCRE Ex. 1. o report of on audit conducted by Applicants' orchitect/ engineer, clearly states that TDI's GA program did not meet 1the.stondords of the performance specification (and thus, GDC 1). (Applicants at the hearing presented testimony intended to~ discredit this document. However, we cannot believe that the long list or flogrant violations over the history of the

. contract presented in OCRE Ex. 1 con be explained away by a lack of personnel support during one particular audit. Christiansen, Tr. 2236-37. We believe that this document is on occurate ossessment of the quality of monufacture of the'PHPP diesel engines.)

Having determined that CDC 1 and 17 have not been complied with, we now focus cur ottention on Applicants' efforts to revolidate the TDI engines. These efforts will be Judged acceptable if, as a result of these efforts, the diesel generators are now found to meet GDC 1 and 17 and the PHPP

. performance specification, D.. THE OWNERS GROUP PROGR H

1. The Owners Group In response to the defictencies in design and manufacture of TDI diesels, obout o-dozen utilities, including CEI, formed the TDI Diesel Generator owners Group. Finding 14. The stated purpose of the OWn rs Group is to is to provide on in-depth assessment of the TDI diesel generators used at the respective nuclear facilities. Kommeyer Testimony at 8. The various parts of the Owners' Group program are described below.

However, it is necessary to understand the true nature of the Owners Group to be able ec ossess its program. Applicones portray the Owners Group as o disinterested tecnnical organi=otion devoted to resolving the problems with the TDI diesels, see, e.g., Kommeyer Testimony; Christzonsen, Tr. 2248-

50. A revtew of the evidence in the recore indicates otherwise.

OCRE Ex. 2, consisting of 3 Owners Group internal documents, deptets on Owners Group extensively c o r. ' with licensing I

schedules (January 10,'1985 Memo'to File), about raising additional' generic concerns'and about the a vasibility or the Owners Group *. setting "the TDI' diesel-generators oport from

~

• Lother make diesel' generators and other plant equipment as needing special consideration * (Proposal for closure of TDI Owners Group). The Owners Group Executive Choir also met with' Mr. Harold Denton, Director or the NRC's Orrice of' Nuclear Reactor Regulation, on1ot least~2 occasions -the matters dtscussed included. relaxing licensing stondords and restrictions,_such as the 195 BMEP limit and maintononce ond surveillance ~ requirements-(January 10, 1985

~

fMamo to File'and Executive summary).

The OCRE Ex. 5 also demonstrates the10 wners Group attitude.

Leomplotnes of the-* ultraconservative' FSAR and the description of the-July 11, 1984. meeting between-NRC, PNL, and the owners

' Group-ore' indicative or on organi otion.more akin to o lobbying-force'such as the Atomic'Indu'strial Forum thon'o disin't'erested 2

~

([~ l

-technical errort.

OCRE'Ex, 4 illustrates Applicones' oescription or the Owners Group goals. ' Note that replacement of the TOI engines was never-4 even considered in the Owners Group program, that there ,is no number or type of failure or quality deficiency considered unocc'eptoble in the diesels, and that it is not the purpose of the Owners Group to drow ccnclusions with respect of any porticular TDI engine'or TDI engines in general. We also note-enot, as early as Horch 9, 1984, long before the completion of g the Owners Group _ Program, Applicones voiced the conclusion that 4 .

k

c

, /f

.. the PHPP diesel engines are not unreliable.

We also~ note that the Owners Group had no objection to full power operation of a unit which had not demonstrated resolution of-the generic Phase I known promlems, osoinst their program recommendation. Staff Ex. 1 at 3.

We must therefore conclude that the Owners Group hos 05 its .

l main goal protecting the commercial interests of its members from the threat posed.thereto by the NRC's regulatory

-octivities. While its program may have some technical n.e r i t ,

its purpose is apparently to Justify the predetermined

' conclusion that the TDI diesel generators are suitable for nuclear service. Contrary to Applicants' assertions, we believe that the Owners. Group interactions with the NRC con be mose

-oppropriately termed ' lobbying.'

Finding 17.

-This conclusion is importone for several reosons. First, it offects the weight we con give to the large number of commitments made by Applicants concerning implementation of

.various ports of the Owners Group program. Secondly, since the Owners-Group has obvsously influenced the NRC Stoff, it offects the weight we con give to the stoff'5 asse2sments of the Owners GrouF efforts. Finally, sznce the Owners Group is engaged in o quality revolidation of the TDI' engines, we must assess it pursuont to the quality assurance program criterio in 10 CFR 50 Appendix s.

Criterson I of. Appendix B, 'Organi:otion*, is applicable.

.This criterion requires quality assurance functions to be sneapendent of commercial considerations. The evidence cited

.i

.- -/f-

.1 obove clearly demonstrates that this criterion was not met. We therefore_must find the Owners-Group program in noncompliance With the Commission's regulations.

2. Elements or the'0wners Group Program

('o ) . Phase I Phase I of the Owners Group effort involved a detoiled design review'of 16 components constdered as significant known

' problems With-generic oPPlicability. Kommeyer Testimony at 12.

These' components are the turbocharger, bose-and bearing caps, crankshort, cylinder block, cylinder head studs, connecting rods, connecting rod bearing shells, pistons, airstort volve c pscrew, cylinder heads, fuel oil injection tubing, pushrods, rocker orm copscrews, Jacket water pump. Wiring and terminations, and cylinder liner. Id.s Finding 15.

The Stoff round that satisfactory resolution of these Phase-I components is o necessory condition for licensing. Finding

19. We agree. Our evoluotion or each of these components is presented in Port E, intro.

(b). Phase II Phase II of the Owners Group program is o design review / quality revolidotion ("DR/QR") errort aimed at those engine components not oedressee in Phose I. Finding 15. The Phase II components are no less important than those in Phase I, but do not have the generic odverse history. Finding 23.

The purpose or the DR/QR program is to compensate for the substandard quality assurance of TDI. Finding 22. The DR/QR

. program ss cased on a lead engine - rollowing engsne concept.

.. _g7 Kommeyer Testimony at 22. Althcush design review . for a lead engine component may be opplicable to following engines, the quality .of manufacture of each following engine must be validated independently. Id.

We agree that validation of each engine is necessary in light of the QA deficienciep, ' identified at TDI. However, the Stoff belteves that the OR/QR effort need.not be completed prior to licensing, and the Staff may never review the DR/QR programs at following' plants. Findings 24-25. We connot agree With the Stofr.on this.motter.

We found obove that GDC 1 has been violated. Before we con approve licensing, there must be reliable evidence that compliance with that regulation has been accomplished through the DR/QR program. Full compliance With the Commission's regulations is mondotory. It connot be argued that a facility

-not. meeting'the regulations is safe anyWoy and thus should be Itcensed. Vermont (Yonkee Nucleor Power Corp. (Vermont Yankee Nuclear Power Station), ALAB-133, 6 AEC 520. 529 (1973). We-therefore rule that Phase II must be fully implemented at PNPP and fully reviewed by the NRC Staff. With a finding that GDC 1 hos been met, before we con opprove of licensing for PNPP.

(c). Engine Testing and I n s p e c t i o.n The third phase of the program involves engine testing and inspection. Finding 99. Applicants have committed to test the diesel generocors in accordance With Regulatory Guide 1.108.

resulting in about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of testing. Finding 100. This coes not oppear to be any different from the testing required pr

v-

, -l8-

.m any diesel' generator, pursuant to regulatory guidance.

According to Applicants, other V-16 TDI engines (Cotowba and

-Comanche Pech) have operated for hundreds of hours successfully (Christiansen Testimony at 27), but we have no independent verification of th25 If we con assume design equivalence among t)-16 engines, testing of lead ~ engines'would be'opplicable ~ to Perry. However, We know that the torsional chorocteristics of the crankshaft differ for each engine. Finding 77. Given the uncertainties regarding crankshaft adequacy (discussed infra), we connot conclude that the proposed preoperational testing is sufficient.

It may be necessory to tent the PNPP diesels for 1E7 cycles to establish their odequacy. Finding 85.

We also hove no assurance that the proposed testing will in fact be performed. We note the NRC Stoff's willingness to rescind its requirements at the request of the Owners Group.

OCRE Ex. 2. Should the tests prove too burdensome or time-consuming, we do not doubt that Applicants will seek relief from the Staff.

(d). Maintenance ona surveillance An enhanced maintenance and surveillance program is the final phase of the owners Group program. Finding 15. The purpose of this program is to ensure reliable diesel op9Potton, in.accordonce with GDC 17. for the life of the plant. Finding

27. Ampropriate maintenance and surveillonce is also o condition of acceptability of many of the Phase I components.

Findings 26, 27.

'O- _. _ _ _ _ . _ , ,

e p -l9 -

n ,. .

Applicants have not yet submitted a complete maintenance and surveillance program, and opparently view survei11once os merely complying with 10 CFR Ports 21 and 50.55(e). Finding 28.

The 5torf is willing to defer the maintenance and surveillance program until-ofter the first refueling outoge.

Finding 29. Even worse, the Starr is willing to re'ax l these requirements.if a licensee were to request it. Finding 31.

Since the Owners Group considers these requirements to be

~

burdensome (Finding 30), we believe that this is likely to occur. .In fact, PNL'hos already relaxed its maintenance and surveillance recommendations. Berlinger, Tr. 2300.

(We note that the Staff.hos rescinded the 185 BHEP limited

~ . . . . --. ..

(Finding 18), predicted in OCRE Ex. 2, os is the relaxation of .

maintenance and surveillonce requ.rements.)

We are not' convinced that such requests would be based on apositive operating experience", as stated by Applicones.

. Kommeyer,-Tr. 2253'. For one thing, there are.no standards for what constitutes such posittve expertence. And, given the limited experience with revolidated TDI engines, it seams unusuoi that such relaxation of requirements would be discussed now. We therefore have no assurance that the maintenance and surveillance program will exist for the life of the plant, or that it will be implemented at all.

Locking such assurance, we cannot find that GDC 17 will be met.for-the life of the >'ont. We must therefore find the use of TDI diesel generators unacceproble.

3. The Storr's Review The Starres review or the prostom and or the diesel generators at PNPP is embodied in Searr Ex. 1, the-5ER on the program. Starr Ex. 2, the SER on the Perry diesels, and Starr Ex. 5, PNL's evoluotion or the operability and reliability or the PHPP engines.

In Stoff Ex,'1 it was concluded that the Owners Group program incorporates the essential elements necessory to ensure-compliance with GDC 1 ond 17. Finding 16. These essential elements are those described above. Findings 15, 16. The Starr also identified certain criteria for interim licensing of racilities using TOI. diesel generators. Finding 18. By interim licensing the Starr meons plant operation prior to Starr review and approval of the findings of the Owners Group one individual licensees (Storr Ex, 1 ot 13) and permitting diesel generator tests and insptccions in parollel with reacto o p e r c.N i o n (Id.,

PNL-TER ot 19), j We connot accept this premise, Applicants have not opplied for on interim licensen what they seek is o full-power, full-term license. We theperore must'evoluote the' reliability of diesel generators for the lire of the plant, at full power, GDC 17 is opplicable'to all phases or plant operation, including low power, and must be complied with as a condition for licensing.

Shoreham, CLI-84-8, supra, We reject the ideo ehot interim

-licensing or a racility with diesel generators or unproven reliability is acceprobles we find it illegal, Unfortunately, this sneerim licensing concepe is the very b.

. 1I-premise or the Storr's conclusions presented at the hearing, Finding 20. In roet, the starr is willing to derer resolution o'r outstonding items identified in SSER 6 until plant operation above 5% power. Finding 33. This apparently stems from the O

Storf's decisior,to let the-Grand Guir plant operate at low Power while teoring down one diesel for inspection, a decision based on o judgement that the diesel generators were not-needed at-low Power operation. Berlinger. Tr. 2394. Since our mandate-15 to ensure compliance with the regulations, and since GDC 17 c

~is applicobie to low power operation, we connot accept this premise. . (ppplicants opparently agree. Tr. 2516.)

(Indeed, it would appear that the Grand Gulr decision itself resulted in a violotton of the single-railure criterion or GDC c

17, even if we were to assume that the remaining diesel generotor-was or proven reliability.)

The Starr's review of the Perry diesels is preliminary.

Finding 20. The Se'orras conclusion that the Perry diesels are relsoble is based on 1) the Owners Group progromi 2) results or inspection and disassembly at Perry Unit li 3) Phase II review conducted for Comanche Peoki 4) previous starr conclusions at Grand Guir, comonche Peak, and Catawbos 5) preliminary rinoings or PNL on the Phone I componentsi and a number of commitments made by Applicants, as to preoperational testing, torsiograph testing, maintenance and surveillonce and other items. Finding 21, Storr Testimony or 12.

We rind these bases to be inadequote. As to"the Owners Group program, we have no evidence that it will be appropriately

r.

. qA-smplemented. os discussed above. Because or the low number or hours the PNPP diesels operated before the teordown and inspection, we are not convinced that the rindings resulting thererror have much significance. Finding 93. The Starr has not' completed its review or the Comanche Peak DR/QR report, and may never review the PNPP report. Berlinger. Tr. 2002: Starr Ex. 2'ot 4 Finding 25. Nor are we convinced that the Comanche Peak report is sufficient for all rollowing engines. We know that some.or the components on the PNPP engines dirrer from those at Comanche Peak. Kommeyer Testimony at 23. There is no. evidence that.

these Perry-specific components have been reviewed by the Starr, or that they ever will be. As for Starr conclusions at other sites, none or Which were conrirmed by a licensing board.in a contested proceeding, we rind that this ' basis

• con be given no weight. We also believe that the Starr decision at Grand Gulf I

was illegal, as discussed above.

As for Applicants' commitments, we have no assurance' that they ws11 be met.

Our decisions must be based on reliable, proboeive, and substantial evidence. Pacific Gas and Electric (Diablo Canyon Nuclear Power Plant, Unit 2), ALAB-254, 8 AEC 1184 (1974). We rind that promises and predictions, however acceptable to the

-Storr, do not meet our stondord.

Indeed, the Starr would have us refer this contested issue to it for Post-heoring resolution, o practice prohibited by the cose low or this agency. See consolidated Edison (Indian Point,

• -A3-Unit 2), CLI-74-23, 7 AEC 951-52-(1974)s Cleveland Electric Illuminatir.g Co. (Ferry Nuclear Power Plant, Units 1 and 2),

ALAB-296, 2 NRC 730, 736-7s Washington Public Power Supply System (Honford Unit 2), ALAB-113, 6 AEC 251, 252; Public Service -Co.4of 'Indiono ( M orb l e H i l l ) ',

• A L A B-4 51', '7 ' NR C ' 313, 318 (1978)s Commonwoolth Edison (Byron Storion Units 1 and 2). LBP-84-2, 19 NRC 36, 210-12 (1984).

We therefore find the Staff's Preliminary conclusions that the PNPP TDI diesel generators are adequate to be unsupported and insufficient for our decision. We also reject the ideo that resolution of open items in the SER con ce delayed until operation above 5% power, or that implementation of certain phases of the Owners Group Program con be deferred until ofter the first refueling outage. If all elements of the Owners Group progran are essential for compliance with GDC 1 and 17 (wn.ch L' O occept), then we require that the progrom be fully implemented and re' viewed, with findings of acceptance supported by reliable evidence, before any licensing,' including fuel load, of PNPP.

4. Conclusions os to Adequacy of the Owners Group Program As discussed above. We have reservations with respect to the adequacy or the Owners Group program, particularly with respect to the implementation Echedule accepted by the Staff. OCRE Ex.

9 Gods to our corcern.

OCRE Ex. 8 is o Port 21 report filed by TDI concerning a failed crankshort oil plug. The Owners Group program did not prevint this failure. Finding 32. We reject Applicants' u.

, .24-chorocteri:otion.of this event as o condom failure (Tr. 2263).

as it was obviously caused by TDI's design change to o thinner.

.goge plug matertal, as explained in OCRE Ex. 8. It is adverse performance such Gs this, attributable to TDI design ond quality s

deficiencies, that the Owners Group program is supposed to prevent. The program railed in its mission.

This event, along with the Owners Group's preoccupation with commeretal interests, deferment of Phase II and maintenance /surveillancs programs until ofter the first

- refueling outage, and uncertainty that the

, ,m . . . . . . . . . . . . . . .

maintenance / surveillance program will'be implemented through the ire of the plant, causes us to conclude that the Owners Group program, as implemented, is insufficient to gain compliance with GDC 1 and 17.

E. PHASE I COMPONENTS 1.

Components not Contested by OCRE Hony of the Phd$e I components Were not contested by OCRE or

.the hearing. We find that these components hove design odequacy. However, we note that many of the components need appropriate maintenance and surveillance to maintain their suitability. Since there is no assurance that a proper maantenance/surveillonce progrom ws11 ever be implemented (or if implemented, that it will remosn in effect for the life of the pione), we connot find these components acceptable for the life of the plant.

We also note that the adequocy of the connecting rod bearing shells and the pushrods is dependent on confirmation of as-

u. -

installed conditions. -See Findings 38, 44.

We will not discuss our findings on these components further. The components and the applicable findings are:

Connecting Rod. Findings 33-36: Connecting Rod Bearing Shells.

Findings 37-38: Pistens. Findings 39-41: Pushrods. Findings42-44s Rocker Arm Copse:'ews. Findings 45-46: Fuel Oil InJeetion e

Tubing. Findings 47-48; Wiring and Terminations. Findings49-50s Airstort Volve Copscrew, Findings 51-53: Cylinder Head Stud, Findings 54-56: Jocket Water Pump, Finding 57-58: Cylinder Heads. Findi 5 59-64.

O. Contestwo ...mponents (a) Engine Bose and Bearing Cops We accept that the base and bearing cops ossembly design is adequate. Findings 65. 67. 68. However, one-of the railures whsch resulted in the inclusion of the base os o Phase I component involved substandard material properties, due to the inclusion of non-r'errous elements in the costing. Findings 65,

66. The finding or design odequacy was based on the assumption of normal material properties. Finding 68. CEI has not Conrirmed that the PNPP engine bases have normal matersal properties. Finding 66.

The Starr believes that such testing is unnecessary, stating thot.unless specific components are broadly suspect. "st con presumed that the monuro0turer has ochieved these chorocteristics.' Starr Testimony at 37-38. However, the monurocturer is suspects that is the reason for the concern With TOI diesel engines. We find the Starr's reasonsng roulty. Nor

. -M-do we takeccomfort in the ossertion'that operating experience has not shown the base to be o problem. Kirkwood. Tr. 2486. We note that TDI has had similar problems with impurities with*

another large costing, the block, made of the some' material, class 40 gray i r o n .' Finding 66. We find that it is necessary to --tes t the base to ,

ensure that it meets ene specified chemical and material properties.

We also note that long-term odequacy of this component is dependent on proper maintenance and surveillance. Finding 68.

(c) Turbochargers

'The turbochargers were included as Phase I components because of several dirrerent problems. Finding 69. We believe

.that the thrust bearing railures con be prevented by the new lubrication systems installed. Finding 70. However, proper maintenance and surveillonce is required to ensure continued bearing odequacy. l Id.

The problem of noc:le ring vone railures is more vexing.

Since the vone failures appear to be attributoble to the no::le ring robrication technique, the problem is not preventable, r Cracking also connot be detected by non-destructive testing tecnniques. Finding 72. Failures have occurred in less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of operation, and are not predictable. Finding 73.

Vane breakage is likely to leod to destruction of the turbocharger. Finding 74.

The Starr claims that enhanced maintenance and surveillos:e will avoid or omeliorate the consequences of vone railure.

F~ j

-2,-

Stoff Testimony at 40-41. But the maintenance and surveillance

o' techniques Will not detect incipient vone failuress rather, they serve to detect vone failure ' ofter the fact.' Findins 75.

Given the severe domo9e potential of this event, We connot find this acceptable.

There is otso the question of Whether the PNPP turbochargers Were properly oligned to their mounting brackets. Findins 71.

This uncertainty, along with the unresolved problem of vone breakoge n leads us to conclude that the turbochargers are not suitable for nuclear service.

(c) Crankshort As previously noted, crocks in the cronkshafts in the TDI diesel generators installed at Shoreham provided one if the bases for admitting OCRE's diesel generator contention in this proceeding. The Shoreham failures, along With other failures of i V-16 crankshafts in non-nuclear sarvice, Were the reason for including the crankshort in Phase I. Finding 76.

Torsiograph t sting of the PNPP diesel 9enerators has shcWn

o. fourth order critical speed of 436 rpm, Within 5% or the rated speec of 450 rpm. Finding 80. The PNPP performance specification prohibits deleterious critical speeds Within 10%

of tne rated speed. Finding 4. The question then becomes, is the critical speed deleterious?

Appliconts claim at is not, as calculations showed that the stresses were within the DEMA alloWobles. Finding 79. However, We question Whether the DEMA guidelines are truly conservative.

The oil hole cracks at son Onofre Were not predicted by torsiograph testing, and the crankshaft there met the DEMA

-x6-standoPds.* Findf69 84. 'ltho0gh-starr A witnesses chorocterized the DENA guidelines os conservative (Tr. 2340), and colled the son Onorre crocks airrelevant" (Tr. 2409), we are not convinced that this is so. We think it is important that the analytical and-tescing techniques being relied upon by Applicants railed to predict the Son Onorre problem.

The fourth order critical speed in question is driven by imbolonce between the right and left banks or cylinders.

Finding 80. The starr considers on evoluotion or cylinder imbolonce to be_necessary. Finding 82. The DEMA guidelines (which are not a design code, Finding 78) do not consider the errects of cylinder imbolonce. Finding 81. The Rules or the Ship classification Societies do consider the errects or cylinder imbolonce, and are conservative. Id. Given.the smportance or cylinder imbolonce in this application, and the s concerns noted above with DEMA standards and torsiograph testing, we rind that evoluotion or the PHPP crankshorts p u r s u'o n t to'the Ship Classification Societies Rules may be more appropriate. We are not convinced that any roctors, such on those mentioned in the Starr Testimony at 25, weigh osoinst the use or these Rules in this opPlication.

Just because the Rules may be opplicable to many engine Sizes and types coes'not mean that they connot be used here. We also note that the performance specification requires the PNPP diesdis to be oble to operate continuously at 7000 kw. Finding

4. Given the uncertainties or extent and du,rotion or loading (Fsndings 6-11), this is a prudent requirement, u

, -llL9 -

+

• We note that the Stoff nos considered adequacy of the PNPP crankshaft to be on open item. Findings 32, 85. Results or the torsiograph . tests must be evoluoted before the crankshaft con be assessed. Id. Depending on t),e outcome of the torsiograph test.. testing to 1E7 cycles may be necessary to qualify the cronkshaft. Finding 85. The Stoff has oiso recommended special maintenanceond' surveillance' procedures'for limiting speed -

ranges and detecting cylinder imbolonce. Finding 83.

.Due to the substantial uncertainties associated with this component (odequacy of DEMA and horsiograph techniques, effects of. cylinder imbolonce, and uncertainties of maintenance / surveillance implementation), we connot conclude that the crankshaft is suitable.for nuclear service.

-(d). Cylinder Block and Liner The cylinder blocks at Shoreham and elsewhere have exhibited four types of. undesirable cracking, thus leading to their trClusion in Phase;I. Finding 86. The Owners Group onolyses or the blocks found that ligoment cracks were predicted to occur.

Finding 87. The Presence of logoment cracks increases the a

possibility of stud-to-stud cracks. Id. The Owners Group performed a cumulative domoge onolysis in order to predict block operating times between inspections. Finding 89.

This analysis does not show that the block con operate continuously at 7000 kw, os required by the PNPP performance specification. Instead, the blocks must be inspected ofter 570 hours0.0066 days <br />0.158 hours <br />9.424603e-4 weeks <br />2.16885e-4 months <br /> of operation. Appliconts have stressed that the PNPP diesels do not operate at 7000 kw continuously (Tr. 2241-44).

. -3o-

'M However, we note that FSAR load predictions have not been verified by testing (Finding 7), that additional loads may be adaed throughout the life or PNPP (Finding 8), that testing or the diesels will tup conducted at 7000 kw (Finding 9), that the maximum frequency of operation during testing is unknown .

(Finding 10), and that the length or time the diesels are needed in on occident is unknown (Finding 11). Given these, uncertainties, and since PHPP*s own specification requires the diesel generators to be o

able to operate continuously at 7000 kW (compare Wood testimony at 86), we rind this to be the oppropriate standard. The blocks, railing to meet this standard, are unocceptable.

We also rind numerous uncertainties whsch' support cur -

conclusion, The Owners Group considers crack depth of 1.5' to be sore. Dr. Bush, o S' torr witness, thinks 0.4-0.5is the coximum acceptable depth. Finding 92. The Owners Group ,

9 onalysis for the cumulative domoge index used crack 9rowth from 1.6 to 3 inches os its basis. Id.

The Owners Group believes that blocks with known or assumed lagoment crocks should be inspected for stud-to-stud cracks .

Orter any operotion above 50% roted lood. Finding 90. Dr. Bush

_f./

thinks the inspection should be performed orter ony operation, due to uncertainties or crock growth. Id.

I The cumulative domoge index calculation used smaller loods or shorter duration than those listed in the FSAR. Finding 89.

Indeed, the ratigue domoge andeX does not actually quantify crack growth, but ts o method or comparison between materials.

.1,/ We khsve, +h:< ny s,heta.ds.lty casace Ahe avallas:Idy o f -+ k an ;seg,

,'s espec to.lly W haael secl dd remval ncessarf. Find.q 91.

. ._st-4 Finding 88. It has not been verified that the PNPP blocks have normal material properties. Finding 94. The supposedly beneficial errect or reducing liner proudness has never been

[

verified. Finding 95.

In light of these substantial-uncertainties, and since the blocks do not conrorm with the performance specification, the only. conclusion we con reach is that the blocks are unocceptable.

F. PHASE'II COMPONENTS

1. Dresser Couplings.

OCRE relt that the Dresser Style 65 couplings used as tube oil and Jocket water rittings are misapplied and should be replaced before plant o p e r c e i o n'. Secrr Testimony at 52. The Starr believes that gradual deterioration is the most likely moae or railures however, o more rapid, substantial railure connot be ruled out. Finding 96. The Starr believes that it would be best to replace the couplings before plant stortup (Id.

'but felt ~that replacement could be delayed until the first refueling outoge. Stoff Testimony at 52. Applicants claim that they will monitor the couplings for looRoge. Christiansen, Tr.

2495.

We are not convinced that monitoring for lookoge will

! prevent or mitigate o substantial railure, which the Starr says

.ss possible. Because the diesel generators provide such a vital t

runction, and must be or high quality, availability, and l

i reltobility (Finding.4), we believe that the questionable couplings must be replaced prior to plant operation.

l l

f I

L' .

2; Foundation OCRE indicated concern regarding the surriciency or contact between the engine base and the chock plants. Finding 97. The

~

Storr-rindsLthat'the roundation setting and olignment are crucial to. engine relsobility. Id. The Starr hos reviewed the portion or OCRE's summary disposition response, including the PNPP nonconformance report on the problem, which raised this issue. Starr: Testimony at 54s Kirkwood, Tr. 2416-19. The NRC Starr1round'the condition or the roundation, and the calculations and evoluotions therfor in the nonconformance report, to be unocceproble. Id.

In their rebuttal Applicants attempted to #Xplain the nonconformang condition. Tr. 2496-97. However, they did not provsde any information which was not previously ovailable to the Storr in the nonconformance report. We are not convinced that the crankshort deflections reported'by Applicants arter only a few hours or operation (Id. Christiansen Testimony at I

33, rootnote 4') are! 1ndicative or long-term conditions.

The uncontradicted evidence on this matter demonstrates that this is on unocceptoble Condition which must be resolved prior to issuance or on operarang license.

II. FINDINGS OF FACT

1. Issue No. 16, as Ismplified by the Board, was admitted as o contention in this proceeding by Nemorondum and Order (New Contention on Diesel Generotors), LBP-83-80, 18 NRC 1404 (1983).

OCRE is the leod intervenor on the issue and the only

-e e - , . , - _ .

& y -

intervenor which porticipated in its litigation.

2. Issue No. 16, as admitted, reads os follows:

Applicant hos not demonstrated that it con reliably generate emergency on-site power by relying on four Transomerico Delavol diesel generators, two ror each or its Perry units.

3. The reur Transomerico Delavol -('TDI*) diesel generators installed at PNPP are DSRV-16-4 engines, Kommeyer testimony at

2. These are TDI R-4 model engsnes, having 16 cylinders arronged in two banks in a V-type engine block, as compared to I

.TDI's DSR-48 which is on inline, 8-cylinder design, Ids Starr Ex. 5 at 2.1. Eoch engine generator set is rated for continuous-operation at 7000 kw and has a short term overload-rating or 7700 kw. Starr Ex. 5 at 2.1.

4. The PHPP~performonee specir~ication for the diesel t ' generators,'5P-562-4540-00, ' Class 1E Diesel Generator-Units, Perry. Nuclear Power Plant. Units 1 and 2', requires that the diesel generators have o minimum continuous rating of 7000-kw, tnot the engine.ond generator unit be free or all deleterious critical speeds or torsional vibrotions within plus.or minus 10%

Dor rated speed at any load from 0 to 110% of rated output, and that the engine be or such quality os to be or high availability and proven reliability. Christiansen, Tr. 2187-88.

- 5. The performance specification has os on ottochment

. specification SP-706-4549-00, 'Monurocturang Quality Assurance program Requirements, Quality Level 1. Electricol*, which imposed a quality assurance program on TDI, to ensure compliance

. .. . ... .~ . . .. -

wsth General Design Criterion 1 and Appendix.B to 10 CFR Port

50. Christionsen, Tr. 2188-90.

1

g

. o. The currently predicted loads on the diesel generators are, Division 1, loss or crisite power with LOCA, 4668 kw, with forced shutdown, 3988 kW Division 2, loop-LOCA, 4130 kw, loop with forced shutdown, 5634 kW. Applicants' Ex. 16-1. ,

7. The octual loads experienced by the diesel generators have not.been verified by testing. Christiansen, Tr. 2215: Storr Ex.

-5, at 2.1. The ability or large motors to reach rated speeds d

before the next-loading step on the diesel generator has also not been verified. OCRE Ex. 6.

8. Additional loads may be added to the diesel generators ,

through the 40 year lire or PNPP. Christiansen, Tr. 2213.

9. Preoperational testing of the diesel generators is to be conducted at a load or 7000 kw. OCRE Ex. 3. Periodic testing or the diesel generators during PNPP operation will-be conducted at 7000 gu, in compliance with Regulatory Guide 1.108.

Christiansen, Tr. 2004.

10. Pursuont to Re9ulatory Guide 1.108, the minimum frequency and duration or diesel generator operation is once per month for at least on hour, and every refueling outoge for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The maximum frequency and durotion or operation is unknoun.

Christiansen, Tr. 2005-6.

11. Since loss or orrsite power con result from severe external events, the length of time orrsite power is lost is not predictable. Christionsen, Kommeyer, Tr. 2221. Thus, the diesel generators must be able to supply on-sste power continuously. Wood Testimony at 96.

12. TDI diesel engines used in both nuclear and non-nuclear

. -3G-applications hove experienced numerous problems with many important components. Starr Testimony at 13. This broad poetern or deficiencies seems from inadequocies in design, monuroeture,-and QA/QC by TDI. Starr Ex. 1 at 1.

13. The quality assurance program at TDI railed to meet the standards of the-performance specification SP-562 and ottochment specification SP-706. OCRE Ex.-1 at 10.

14. In response to the problems with TDI engines, about a do:en utilities, includin9 CEI, formed on Owners Group, which developed a program for resolving these concerns. Kommeyer c Testimony at 7-9; Starr Ex. 1 at 2.

15. The essential elements of the Owners' Group program are Phase I, resolution or sixteen known ' problem' components (which are the turbochar9er, engine base and bearing cops, crankshort, cylinder-block, cylinder liner, cylinder head studs, connecting rods, connecting rod bearing shells, pistons, airstort volve capscrews, cylinder heads, fuel oil injection tubing, pushrods, f -

i rocker arm capscrews, Jocket water pump, and wiring and terminations): Phase II, o design review / quality f revalidation s

(*DR/QR*) program for components not addressed in Phase Is engine testing and inspection; and enhanced maintenance and surveillonce programs. Starr Ex. 1 at pp. 2-11s Kommeyer Testimony at 10-25.

16. The NRC Starr concluded that these four essential elements or the Owners Grcup program ore necessory to ensure that the TDI diesel engines comply with General Design Criterio 1 and 17, 5torf Ex. 1 at o.

, 36 -

17. The Owners Group did not Just. perform technical evoluotions, but also acted as o ' lobbying' influence on the NRC starr so os to gain'the starr's concurrence with the Owners Group's predetermined conclusion that the TDI engines are reliable. OCRE Ex. 2i OCRE Ex. 4: OCRE Ex. 5.

18. The Starr identified a number or criterio ror interim licensing of plants using TDI diesels, including limiting the lood to 185 psig broke mean errective pressure. Starr Ex. 1 at 13-14. However, the Starr is.willing to relax this lood restriction. OCRE Ex. 2. This hos been cone for Perry, ce

. . .. m .-. . . . . . . .

CEI's request. 'OCRE Ex. 3: Christiansen, Tr. 2201.

19. The Starr has concluded that TDI engsne owners muse satisroctortly address the Phase I components as a condition for licensing. Storr Ex. 1 at 7.

20. The Storr's review or the PNPP diesels is preliminary.

Stoff Ex. 5 at 1.15-Starr Ex. 2 at 4. The final SER will be issued orter the first refueling outage. Berlinger, Tr. 2305.

21. The Storr's conclusions os to the adequocy of the PHPP ctesels, ore based on previous Storr conclusions for_other engines, preliminary Phase II reviews for onother engine, preliminary Phase I rindings, and a number or commitments made my Applicants, starr Testimony at 12: Starr Ex. 2 at 1-2, 9-12.

22. - The purpose or the Phase II DR/QR Program is to compensate for the QA deficiencies at TDI. Kommeyer, Tr. 2192, 22406 Berlinger, Tr. 2316. Although design revsews for lead engine components con imply ocequacy for those in rollowing engines, the quality or manurocture and construction must validated o

independently for rollowing engines. Starr Testimony at 17,

23. The components evoluoted under Phase II are important to engine operability, but do not have a history or odVerse performance, os do the Phase I components. Dingee, Tr. 2461.

24. The-Storr does not-consider completion or Phase II to be necessary prior to licensing. Berlinger, Tr. 2507s Dingee, Tr.

24531.Storr Ex. 1 at 8.

R2 5. The NRC Starr may never complete its review or Phase II evoluotions at following plants. Berlinger, Tr. 2303-4. In roct, the NRC*5 TDI project' group plans to disbond orter a completion of generic aspects or its review. Berlinger, Tr.

2303-4.

26. Appliconts commissioned Southwest Research Institute

('SwRI') . to perf orm on independent review or the owners Group evoluotions or Phase I components. Christionsen at 7-8. SwRI concluded that the 16 Phase I componenes are suitable for nuclear service provided that maintenance and surveillance I

recommendations of SwRI and the Owners Group are rollowed. Wood Testimony at 3, 875-Wood, Tr. 2181.

27. The 11RC Starr hos likewise found that enhanced maintenance and surveillance is necessary to ensure that the diesels Will C meet GDC 17 for the lire or the plant. Berlinger, Tr. 2468s Starr Testimony at 15, 16, 20: Starr Ex. 1 at 10. The Starr h'os

-also round that enhanced maintenance and surveillance is o condition for acceptability of some or the Phase I components.

Starr Ex. 4.

28. Applicants

• maintenance and surveillance program os presented in the DR/QR report is incomplete os it does not

. 30-

,w w...

include surveillonce requirements, starr Ex. 5 at 6.1.

Applicants.opparently view surveillance for the diesel generators os.merely-Complying with 10 CFR 21 and'50.55(e).

- Christiansen Testimony at 19,

29. The NRC.Storr is willing to derer implementation or the maintononce and surveillance requirements until arter the first refueling outoge. Berlinger, Tr. 2305.

. 30. The Owners Group considers the maintenance and surveillonee requirements to be time consuming and burdensome. Kommeyer, Tr.

2253 Berlinger, Tr. 2299.

31. The NRC Starr is willing to relox the maintenance and

- surveillonce requirements ir requested by licensees. OCRE Ex.

2.

32. The Owners Group program has railed to prevent further adverse experience with diesel components attributoble to TDI design ond/or QA-deficiencies. OCRE Ex. Os Kommeyer, Tr. 2230. ,

33.- The NRC Starr believes that outstanding items concerning h

aissel reliability: ideneiried in SSER 6 need not be addressed cercre operation or PHPP obove 57. power. Sterono, Tr. 2474.

34. Connecting Rod. The connecting rod was evoluoted as a Fhose I component _ because or the railure history associated with assemblies using 1-7/8' bolts. Wood Testimony at 82. PNPP is supplied with the new cesign which utilaces 1-1/2' bolts. Id.

The change in bolt diameter provides a greater material section, l

and reduces stress levels, in the master rod box. Id. There have been no railures with the 1-1/2' bolts at the currently-specified torque level. Berlinger, Tr. 2435-37.

35. In its evoluccion of this component, the CWners Group

, -39 ~

identified the railure mechonisms and performed a rinite element stress'onalysis to predict performance in nuclear applications.

Wood Testzmony at 83-84. Results were compared to experimeneo dato and operating history. Id. at 84. There is no history or buckling of V-engine. connecting rods; the Starr does not recommend a buckling strength analysis. Storr Testimony at 32 Henriksen, Tr. 2435. Nor have there been any railures of a wrist pin bushing in a TDI engine. Starr Testimony at 32-33, o

36. T,he NRC Starr concurs with the Owners Group and SwRI that the PNPP connecting rods are suitable for their intended service. Starr Testimony at 6 Wood Testzmony at 84-86.

Houever, preventive maintenance, including bolt torque checks, is required to ensure continued suitability. Starr Testimony oe 6: Storf Ex. 4.

37. Connecting Rod Bearing Shells. Connecting rod bearing shells were reviewed as o Phase.I component due to crocked f

bearing shells at Shoreham. Wood Testimony at 21-22. The large (1/4" x 45 degree) chamrer at Shoreham which caused the crocking has been rep 100ed by a smaller (1/16' x 45 degree) design. Id.

at 22. The Owners Group analysis included Journal orbit analysis, tensile properties tests, finite element stress onalysis and a fracture mechanics analysis. Id. ot 22-23. SWRI performed on coditional onolysis to calculate oil film thickness and pressure for the hsgher peak Cylinder firing pressure in the PNPP engines. Id. or 24-25. SwRI ogreed with the Owners Group conclusion that the PNPP bearing shells have o ratigue life of

.e LQ =

. . . ,, .3,_ ,,. ,

38,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> or rull lood operation. I d .' at 25,

38. The connecting rod bearings in place at PNPP have been

~

inspected, per Owners Group requirements, and round to meet the Owners Group criteria for acceptance.. Id. at 26. The NRC Starr b4 lieves that bearings which meet,the Owners Group occeptance criterio are odequate ror their intended service. Stoff

. Testimony at 36. However, the Starr requires that PNPP verify the odequacy or oil. installed bearings. Id. at 36. ,

39. Pistons. Piston skirts were included among the Phase I components due to cracking in the skirt-to-crown stud attachment mosses in AF pistons at Shoreham. Wood Testimony at 50. The PNPP engines have AE pistons. Id. or 50. The moJor dirrorence netween the two designs is in their robrication thermal history and the configurotson of the stud bosses inside the skirt where the wasners on the crown ottochment stud meet the skirt. Id. ot -

50. The heat treatment for the AE skirts results in less terrike than in th[e AF skirts, making the AE skirts structurally stronger. Id. 51. Residual seresses are for less in AE skirts than in AF skirts os well. Id. ot 51.

40. The owners Group evoluotson or the paston included destructive and nondestructive examinations or o railed AF piston, experimento1 stress onalysis and finite element

-onolysis. Id. ot 50-53. The Owners Group and SwRI concluded l that the AE piston skirts are adequote for unlimited lire under rull lood conditions. Id. ot 55. The PNPP AE piston skirts hove been confirmed to satisry Owners Group occeptance criterso, j Starr Testimony ot 27. The NRC Starr concludes that they will l

_yg

--ie.- --

perform satisroctorily. Id. or 28.

41. OCRE expressed concern over Fretting in AE pistons and instances or chrome rioking. .See, e.g., Starr Testimony at 26.

The instances or rretting that have been observed between the

~

crown and skirt or AE pistons have not been serious. Henriksen,

'Tr. 2426-.27:. . . .St.arr Testi. mony at 26. Nor have ony instances of

. , ._ s .

chrome floking from piston rings and wrist pins resulted in'ony serious domoge. Starr Testimony at 26.

42. Pushrods. The PHPP pushrods are of the friction-welded design.. Wood Testimony at 39. No railures have been reported for this design. Id. Problems with two other designs (forged head and ball end) resulted in the inclusion or pushrods omong the Phase I componenes. Id.

43. The Owners Group investigation or the puhrod included meto11urgical, ratigue and buckling stability / wear resistance onolyses or the various designs. I d'. ot 38-39. SWRI extended the Owners Group buckling analysis to include buckling under I

dynamic icooing conditions. Id. ot 39. The Owners Group onalysis of critical loading yielded sorety roctors or 6.1 and 2.3 for the intoke and exhaust pushrods and 2.1 for the exhaust intermediate pushrod. Id. or 40. The rotigue crack analysis indicated that, under cyclic loading, any potential robrication crack is not expected to propogote in either the main or intermediate reiction-welded pushrods. Id. Nondestructive examinations performed before and orter rotigue testing or the intermediate pushrod showed no riows. Id. ot 40-41. The meto11urgical evoluotion or

_qt- -

e the friction-welded design showed typical microstructures for the materials. Id. at 41. Based on its analysis, the Owners dr'oup concluded that the friction-welded design is the most reliables SWRI concurred. Id. at 42.

44. PNL has oise concluded that the PNPP pushrods are odequate for their intended service, given their rovorable operating history'and the satisroctory results obtained in PNPP*s liquid

' penetrant examination or its pushrods. Starr Ex. 5 at 4.24-4.

However, the NRC Starr requires that CEI confirm that the pushrods installed at PNPP are from a lot that has been sucjected to destructive examination or o rondom sample. Starr Testimony or 10.

. . . , s .. . - .

.. ,, .= e

45. Rocker Arm Copscrews. Rocker arm copscrews were evoluoted as a Phase I component due to isolated.roilures resulting from insufricient preload opplication. Wood Testimony at 6. The -

Owners Group analysis included a ratigue life analysis, thread cis tortion analysis', thermal stress evoluotion, and a determination or the applied stress and endurance limits of the two copscrew designs in use. Id. at 7.

44. Based on their onalyses, both the Owners Group and SwRI concluded that the rocker arm copscrews utili:ed at PNPP are adequate for nuclear service. Id. at 10. However, proper mosntenance and surves11once is necessory to guard against loss or prelood. Id. or 10-11: Starr Ex. 4. Based on PHPP's snspection or this componene, onolytical evidence and rovorable operating history. PNL otso concluded that the copscrew is suttable for use at PflPP. Storr Ex. 5 or 4.07.

s

~43-4 7.- Fuel'OiluInjection Tubing. Fuel oil injection tubing was revtewoo os o Phase ITcomponent due to. problems with leakage.

Wood Testimony at 11. The'0wners' Group analysis included on investigation of applied stresses on the tubing and comparison

_ with~its' yield strength and endurance limits, os well as a rrocture mechanics analysis. Id. at 12.

o48. Both'the owners Group and SWRI concluded that the tubing in place at PNPP is adequate for continued uses this determination-was bosed, in port, on PNPP's inspection or its tubing using eddy current techniques to assure the obsence or flows. Id. at 13-14; Christions'en Testimony ot 7. PNL concurs that the tubing

. is suitable for ses intended use. Starr Ex. 5 at 4.33.

However, PNL recommends thoe compression ritesngs be pertodically checked'ror leaks. Id..at 4.32-4.33,

49. Wiring and Terminotions. Wiring and terminations were ,

included.as Phase I components as a result or TDI's identification or t,Wo potentially defective engine-mounted cables that did not meet IEE,E-383,-1974 standards. _ ,

Wood , , ,

Testimony o t, 2 7. The owners Group performed on evoluccion or

)

both TDI-generic and PilPP-specific designs. Id. The analysis included a review or the circuit requirements, including a determination or the wire insulation roting, type, and rating or termination voltage, maximum temperature, riame recordoney i

i l requirements and routing. Id.

50. The Owners Group onolyses resulted in o conclusion that the Pi1PP wiring and terminotsons are satisroctory: SwRI agreed with this conclusion. Id. at 28-29. PflL concurs that PNPP's wiring l

l b

7

. _qq_

e and terminations are suitable for their intended use. Starr Ex.

5 at 4.36.

I

51. 'Airstort Volve copscrew. The oirstart volve copscrew was evoluoted by the Owners-Group as a Phase I component because

.copscrews supp1 sed to one utility by TDI were too long for their bolt holess this. prevented the volves from_being properly seated. Wood Testimony ot-34. A stress and dimensional analysis.was performed for the capscrew by the Owners Group.

Id., SwRI otso performed a number or onalyses to evoluote the runctional attributes or the.copscrew, with no signiricant dirrerence in results from those obtained by the Owners Group.

Id. or 35-36.

52. PNPP has inspected the bolt holes depth for every airstort volve copscrew on_its engines to verify that they are the appropriate length so that the copscrews will not bottom out.

Christiansen. Tr. 2223: Persinko. Tr. 2420-21.

53. Both SwRI and the owners Group concluded that the airstart volve copscrew was or adequate design and satisroctory for nuclear service. Wood Testimony at 36. PNL concurs that the capscrew design is adequate. Starr Ex. 5 at 4.35.

However. both SwRI and PNL recommend that maintenance and <

surveillance regarding proper torquing be conducted . Starr Ex.

45 Wood Testimony oe 37.

54. Cylinder Head studs. Cylinder head studs were evoluoted as o Phase I component by the owners Group due to isolated railures os o result of insufficient prelood. Wood Testimony at 29. A stress onclysis or both head stud designs (straight and necked a

.- -qs-shank) was performed by the Owners Grour. Id. ot 30. SwRI's revsew of the Owners. Group results did not yield any significont dir 'rences. Id. at 31.

$. trrormed the.0wners Group recommended material verification and confsrmed that its cylinder hood studs meet AISI'4140 stondords. Io, or 32-33,

56. Both the Owners Group and SWRI concluded that either cylinder head stud design is satisfactory. Id. at 32-33. PNL concurs. Stoff Ex. 5 at 4.23. The necked design (utilized at

.PNPP) was recommended by SwRI because i t- is less likely to lose [

its prelood, has a higher safety factor under fatigue loading and lowers the. Stresses in the block odjacent to the liner landing. Wood Testimony at 33. Proper maintenance is necessary to ' ensure that preload is maintained. Staff Ex. 4s Wood Testimony at 33.

57. Jocket Woeer Pump. The jocket water pump,used on the 05RV-16 engines does not have o history of failure. Wood Testimony at 69. The-Jacket water pump received o detailed design review by the Owners Group due to roilures on the inline, DSR-48 engines at Shoreham. Id. The Ouners Group onalysis included a In c torsional onalysis and a seress onolysis. Id. ot 70-71.

conducting its review or the owners Group onolysis, SwRI took into account the smaller diometer of the PNPp pump impe11ers.

Id. ok 73. SwRI also considered impeller rotation and the errects of stresses due to centrifugal force on the drive fst.

Id.

59. Based on its analysts, the Owners Group concluded that the

</4 -

pump design at PNPP-was adequate for nuclear service. Id. or

71. SWRI concurred with the Owners Group evoluotion as it applied to PNPP. Id. at 73. PNL oiso concurs wuth the Owners Group evoluotion, starr Ex. 5 at 4.31.

59. Cylinder Heads. Cylinder heads were evolunted by the Owners Group as o Phase I component because of cracking observed in a number of locations on the heads. Wood Test.imony at 44.

The Owners-Group evoluotion included a metallurgical onolysis, on evoluotion of' thermal and pressure stresses on the head and modeling of the component. Id. at 44-46.

~

60. The cylinoer heads in use at PNPP have all meen stress-relieved one welded to meet new requirements. Storf Testimony or 6; Kommeyer. Tr. 2 34-35. Because of this treatment, the PNPP cylinder heads are not subject to volve seot cracking, o concern raised by OCRE or the ' seat ing. Kommeyer. Tr. 2232-35.

61. PNL consi'ders it importone that none of the PNPP heads have through-woll weld repatrs performed on one side only, due to the stress concentration ossociated with.such a repair. Stoff Ex. 5 or 4.20. The cylinder heads in place at PNPP do not have such weld rePoirs. Berlinger. Tr. 2428-29.

62. All of the cyltnoer heads meet mimimum rire deck thickness requtrements. Airkwooc. Tr. 2431. However, the Staff found that the thickness patterns appeared inconsistent for several of the heads, o condition which would worront maintaining spore n e o d s'. Stoff Testimony at 31: Kirkwood, Berlinger. Tr. 2432.

63. It is necessary that oppropriote motntenance and surveillance procedures, includsng otr-rolling the engines ofter

m 41-oll, operations and before all planned starts to check for Possible woeer leakoge into the cylinders from cylinder head cracks. be implementea. Starr Ex. 4s starr Testimony at 6:

Starr Ex. 5 or 4.01, e4. The Owners Group and SwRI concluded that the cylinder heads used at PHPP ore odequate. Wood Testimony at 48. The cylinder head design is considered ocequate by the NRC Starr and PNL.

based primarily on operottonoi history. Henriksen. Tr. 2427.

65. Engine Bose and Bearing caps. The engine base.and bearing

.) . , .

s .

cops ossembly was included among the 16 Phase I components die

o cracking observed in inline DSR-4 engines. o nut pocket railure f.n o 05RV-16 engine, and through-bolt railures on a DSR-

+4 engine. Wood Testimony at 16. The owners Group performed a ratigue and fracture mechantcs onolysis and stress analysis for both the saddle and caps. Id. at 16-17. The through-bolts and bearing cap and rostener system were also evoluoted. Id. or 18-

19. SwRI's review;or the Owners Group onalysis indicated that the interroce between the cop and silddle was even stronger than calculated by the Owners Group. Id. or 19. This means that there will be no lateral movement of the cop under the influence of the crankshort horizontal force. Id. ot 19-20.

os. The instonce or nut pocket railure in the Anomox mine V-16 l engine was due to material obnormolities, specifico11y, to non-l l rerrous impurities in the casesng. Kommeyer, Tr. 0216:

Kirkwood, Tr. 2350. cyltnder blocks, which are, like the base, i

large costings mode from Class 40 gray cost iron, hove also l

surfered from degenerate materici properties due to non-rerrous

[

i

• - -y g .

impurities. Bush. Tr. 0350-51. There is enough concern for the block material properties to require on evoluotion or each a

block. Dingee Tr. 2350. However, CEI did not conduct any chemical cr.meto11urgical evoluotions or the base, but relied on material certifications supplied by TDI. Kommeyer, Tr. 2216-17, 0505. ,

67. Inspection or the No. 5 bearing saddle, pursuant to the Owners Group program, revealed linear indscations, which have been characteri:ed os minor costing indicotions common in large Kommeyer, Tr. 0015-16 5torf Ex. 5 at 4.3. Because costings.

of the large factor of sorety (greater than 15.8) osainst grouth or such small Endicottons, it Was' Considered unnecessory to remove them. Kommeyer, Tr. 2018. Both the NRC Starr and PNL ogree that the indications are not a cause for concern. Storr Testimony at 38. . . . . .. . .... . . .

. . ~ ~ '

68. The Cuners Group evoluotion or the base assemb1y components showed that they h0Ve sufficient strength to operate for indefinite periods at full lood, provided that the base costing and bolting components meet their nominal material and dimenssonal specifications, that components hoYe not been' domoged, and that bolt torque dpecifications are held, Starr Ex. 5 at 4.0. PNL ogrees that the ossembly is adequate for its intended service. Io. or 4.3. However, mosneenance and surves11once procedures are necessary to ensure continued suitobility for nuclear service. Id.: Storr Ex. 4.

69. Turbochargers. The turbochargers were included among the Phase I componenes because or enrust bearing and no::le ring and vone foilures on TOI nuclear stondey engines. Wood Testimony at

. -yy_

64. The Owners Group performed a number of analyses to determine loading and the load carrying copobility of the turbocharger components. Id. at 64-65. The Owners Group

.onalysib of no::le ring capscrew, washer, and vone foilures determ'ined the proboble cause of the single ring failure (impact from o broken vone) and vone railures (high cycle fatigue).

Id. or 67.

70. The thrust bearing failures were attributed to inadequate lubrication during rost stores. Storr Ex. 4: Starr Testimony o r, e

39. The use or prelubrication systems.should prevent thrust bearing Weor. Id.; Wood Testimony at 68. However, SwRI has recommended that specific motntenance and surveillance practices be implemented to ensure continued bearing odequacy. Id.

71. The PNPP turbochorger mounting brockets were redrilled to relieve misalignments. Turbocharger mounting misolignment is o serious threat to turbocnorger operation. Redrilling may or may ,

d not be on effective remedy. Any solution to turbocharger I

masolignment must be engineered in advance, and its effectiveness verified in operation. Staff Testimony at 41-42,

72. The turbocharger no::le ring robrication technique causes

~a , -

high Stress concentratton at the Vane roots, Which, With vibrotton, promotes vone breakoge. Bush. Tr. 2353. Fotigue cracks initiate below the hub surface and connot be detected by visual or laquad penetrant inspections. Berlinger, Tr. 0354 Dinsee, Tr. 2470.

73. Vane failures nove occurred in less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> or engine operation. Kirkwood, Tr. 2354: Stoff Testimony at 39.

It 15 not posfible to predict wher. O Vane will foil. KirkWood,

r;-

• ~

. gg _

9 Bush. Tr. 2357.

74. Operational experience indicates that vore railures may occur on the-PNPP turbochargers in the future. Starr Tesesmony at 39. It as'likely that vone breakage will cause the turbocharger to be severely domoged or demolished, although these consequences have not yet been observed in . nuclear turbochargers surrering vone railure. Starr Testimony at 40s Henriksen, Tr. 2443-45, 2459-60.

75. The maintenance and surveillance procedures (inspection for missing vones and monitoring exhaust temperature) recommended

~ror this problem are unoble to detect incipient vone roilure.

Starr Testimony at 411 Christiansen. Tr. 2490s Kirkwood, Tr.

2354-55.

76. crankshort. The Perry diesel generators have 13' x 13' crankshorts. Wood Testimony at 74. The DSRV-16-4 crankshorts

.were included in Phase I because or three crankshort railures in non-nuclear applications. Id. The Owners Group review included l

O dynamic torsional analysis and a modal superposition analysis

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

of the crankshort for PNPP. Id. ot 78-80.

77. Because or diferences in generator and flywheel s

chorocteristses from engine to engine, torssonal stresses are dirrerene for each engine, storr Ex. 5 at 4.93 Storr Ex. 1 (PNL TER) at 7s Hardy. Tr. 2477-78. Thus, separote torsiograph testing for each plant is required. Id.

78. .The P.NPP cronkshorts are required ,to meet the recommendations or the Diesel Engine Monurocturers Association

(*DEMA'). Wood Testtmony at 75. The DEHA recommendations are not a design code, and are octually guidelines. Berlinger,

e *

, Hardy. Tr. 2339. DEMA recommends that no harmful torsional vibrotory Stresses occur within 5% obove and below rated speed.

Wood Testimony at 75. PNPP's performance specification is even more string 9nts the engines were required to be free of all-deleterious critical speeds or torsionci Vibrations for any operating speed within the range of 90% to 100% or rated speed at any load from 0 to 110% of.roted output. Christiansen. Tr.

2107. The DEMA recommendottons state that crankshaft torsional vibrotory conditions shall generally be considered safe when thdy induce o superimposed stress of less than 5000 psi, created by a single order of vibration, or o superimposed stress or less than 7000 psi, created by summing the major orders of vibration. Wood Testimony at 75. .

79. The Owners Group analysis found that Cronkshaft stresses were within the DEMA guidelines, Wood Testimony at 78-80.

However, torsiogroph testing is required to confirm these l

coleulati ns. Id. or 81.

96. Torsiogroph tests on the PNPP Unit i engines andicate that the crankshaft hos a fourth order critical speed of 436 rpm.

Kommeyer. Tr. 2045. The driving force for the fourth order critical is imbolonce between the right and left cylinder banks.

Wood Testimony at 79 Kommeyer. Tr. 0045, 2511.

81. The DEHA guidelines do not consider the errects or cylsnder smoolonce. Hardy, Tr, 0339. The Rules of the Ship Classification Societies do consider cylinder imbolonce, and are conservative. Hordy, Henriksen. Tr. 2340.

- s2. -

e

82. PNL cannot formulate final conclusions on the adequacy or the PNPP crankshorts until torsional analyses and confirming torsiograph information have been reviewed. Starr Ex. 5 at 4.

.e .

w.

The Starr believes that the errects or cylinder imbolonce should be investigated. Starr Testimony at 9, 25.

83. The Starr hos recommenced special maintenance and surveillance procedures With respect to the crankshort, including special monitoring to detect cylinder'imbolonce and limitorion or engine speed range. Starr Testimony at 9.

84. Cronkshorts at son Onorre, Which uses TOI V-20 engines, developed ratigue cracks in the oil holes of the main Journois.

Storr Ex. 1, Cover letters Hardy, Tr. 2326. These crocks, had they not been removed, could have caused crankshort railure.

Berlinger, Tr. 2331. The San Onorre crankshorts met the DEMA guidelines. Berlinger, Tr. 2327. stoody-state stresses determined from torstograph tests Were too low to explain the-crocking. Hardy, Tr. 2326-27. The cracks were attributed to high stresses during rost starts. Hardy, Tr. 2327. Only one or three torsiogrCDh tests conducted on the Son Onorre engine shoWed high stresses, due to sensitivity to initial cronkshort position.

Berlinger, Hardy, Tr. 2328-30,

85. Depending on the out'come of the torsiograph and analysis, further testing (testing to 1E7 cycles, approximately 750 neurs at 450 rpm) moy be needed to quality the crankshort. Starr Ex.

$ or 3.2s Berlinger. Tr. 2323.

86. Cylinder Block and Liner. The cylinder blacks were included omong the Phase I components because of block crocking

, at Shoreham and elsewhere. Wood Testimony at 56. Four types or cracking were identifieds 1) ligoment cracks (from cylinder liner counterbore to head stud counterbore): 2) stud-to-studs 3) stud-to-end or blocks 4) circumferential erocks at the liner counterbore. Id. All of these cracks are undesirable.

Berlinger, Tr. 2361.

87. The Owners Group _onalysis included strain sage testing, o meto11urgical analysis, and te,ns,ile and _.ratigue tests of the block. Wood Testimony at 58-60. These analyses round that lagoment crocks are predicted to. occur, and that their presence then increoSen stresses in the block and increases the likelihood or stud-to-stud cracks. Stoff Ex. 5 at 4.5.

88. The Owners Group produced o cumulative ratigue domoge index which occounts for hours of operation at dirrerent power levels one corresponding mean and cyclic stress at each level. Wood Testimony at 60. The Owners Group reacture and ratigue life evoluotion produced o cumulative domoge onolysis Which opplies I

this index and can'be used to set future engine operation limits. Id. ot 60-61. However, the ratigue domoge index does not really establish quantitatively the extent or crack growth rather, it is o method or comportson betWeen dirrerent makersols, Bush, Tr. 2450.

39. The cumulative domoge onolysis did not show that the blocks are acceptoble for continuous operationi rather, they must be inspected orter 572 hours0.00662 days <br />0.159 hours <br />9.457672e-4 weeks <br />2.17646e-4 months <br /> or operoeton or 7000 kw. Kommeyer, Tr. 2194-95. There is some margin, so that engine operation arter this period, e.g., for o LOOP /LOCA. is permitted.

Kommeyer, Tr. 0220, 2269. The LOOP /LOCA loads assumed for this

w -

9:

analysis were 4460 kw for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. Exhibit A to Kommeyer Tastimony at 2. The FSAR loo'd preeschions show that the peak-load or PHPP is 5634 kw, and o load or 5630 kw will persist for 087 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br />. Applicants Ex. 16-11 Christiansen, Tr. 2244.

90. The Owners Group recommends that cylinder blocks with known or assumed ligoment crocks should be inspected for stud-to-stud cracks arter any operation in excess of 50% or nomeplate loading. Wood Testimony at 60. However, Dr. Bush, one or tne NRC Starr' witnesses, believes that this inspection should be performea creer any operation, os there is no adequate basis ror concluding that crack growth would arrest. Bush, Tr. 2371.

91. Dr. Bush believes that crack initiation may occur in the thread region or the studs, which Would require stud removal and eddy current inspection for their detection. Bush, Tr. 2371-72.

92. The Owners Group believes that stud-to-stud crocks which L extend less than 1.5' from the block top are oceeptable. Wood Testimony at 62. Dr. Bush disagrees with this conclusion, and believes that indicottons should be limited to 0.4-0.5* deeps at thoe point, the block should be replaced. Bush, Tr. 0372-73.

L However, the cumulative domoge index used crack growth from 1.6 to 3 inches as its basis. Kommeyer, Tr. 2071.

93. PHPP's 100% inspection of cyttnder block tops one liner landings found no evidence of any crocking or the block tops.

Christionsen, Kommeyer, Tr. 0002. However, the engines had very i

rew operating hours at the time of this inspection. Starr Ex. 5

! ot 7.11 Bush. Tr. 0413.

94. The presence or degenerate microstructure (Widmonstoetten graphite) in a block will degrade its mechanical propertiess l

L

~

. ~ 55 -

. this was observed in the Shoreham EDG103 block. Wood Testimony at 59-60. The Owners Group and SwRI recommended that the PHPP cylsneer blocks be subjected to metallurgical evoluotion to verify that the microstructure is chorocteristic of typscal g /oy cost iron. Id. or 62. Although it is reported that the PNPP blocks have normal microstructure, this has not been verified by the NRC Storr. Bush. Berlinger, Dingee, Tr. 2410-11.

95. cylinder liner proudness has been reduced at PNPP to reduce the pressure on the liner and thereby reduce the possibility or block cracking. Henriksen. Persinko, Tr. 2447-48. cylinder liner proudness has been reduced down to two mils, thereby maintaining liner crush, Persinko. Tr. 2448 Christiansen, Tr.

2508. However, the Owners Group's consultant, FoAA, never opproved the reduction in proudness. Starr Testimony at 40.

The errectivness or reduced proudness in reducing stress levels nos never been determined. Kommeyer, Tr. 2500-09.

96. OCRE rett that the Dresser Style 65 couplings on the PHPP engi.nes should be replaced prior to plant operation, . see starr Testimony oc 52. While the Starr believes that gradual deterioration or the gosket is the most likely mode or railure, it ts possible thor o rapid, more substantial railure is possible. Id. The starr believes that the coupling would be best replaced before plant startup. Id.

97. OCRE indicated concern regarding the surriciency or the contoce between the engine base and chocks, see starr Testimony at 54-55. The Storr views proper roundation setting ond-olignment as cructol to reliable engine service. Id. The storr has round the conditton at PHPP, and Appisconts' evoluottons

- S6 -

• - enereof, to me unocceproble. Kirkwood. Tr. 2416-19.

98. At the time of the hearing, the PNPP Division 1 engine had J

run for opproximately 13-1/2 hours and the Division 2 engine had run for opproximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. Christionten Testimony at 31-32,

99. The third phase of the Owners Group program involved o complete disassembly of the PHPP engines. t: heir inspection and reassembly under PHPP's quality c o r, t r o l and quality assurance program. Christiansen. Tr. 2499 bommeyer. Tr. 2182s Christiansen Testimony at 11. Raplacemet oi compone.nts and routine maintenance on the engines were also petformed during this time. Id. or 7. ils Christiansen. Tr. 2499.

100. Preoperational testang of the diesel generators will reportedly be in accordance with Regulatory Guide 1.108 and will result in opproximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of testing. Stoff Testimony oc 10s Christiansen Testimony at 29.

III. CONCLUSICHS OF LAW

1. Applicants.have met their burden or proof with respect to i

l the design adequacy of the folloWang components:

l l

connechtng roci connecting rod bearing shellsi pistonst

pushrods; rocker arm copscrews fuel oil injection tubing i

l wiring and terminotionsi oirstart volve capscrews cylinder heod studs jocket water pumps and cylinder heads.

2. Applicants have met their burden of proof with respect to '

the design adequacy of the engine base and bearing cops ossemblys however, they have not demonstrated that the base hos the specified mechonical properties.

3. Applicants hove met their burden of proof with respect to the

r 57 -

9 turbocharger thrust bearing lubrication systems, but have failed A

to meet their burden of proof with respect to turbochorger mounting olignment and no::le ring inlet vone failures.

4. Applicants have not met their burden of proof with respect to the following components:

crankshafts block and liners Dresser couplings,used in lube oil and Jocket Water systemsg engine foundation.

5. -Applicants have failed to meet their burden of proof with respect to the adequacy of the Owners Group program os to its lock of independence from commercial interests, the implementation of Phase II, preoperational testing requirements, and maintenance / surveillance requirements, and its inability to prevent further failures attributoble to TDI's substandard practices.

IV. ORDER WHEREFORE, IT IS ORDERED

1. The opplication for operating licenses for the Perry Nuclear Power Plant, Units 1 ond 2, is DENIED.

2. Pursuont' to 10 CFR 2.760(o),' thts is o portici initial decision that Will constitute rtnol action of the Commission forty-rive (45) days from the date of issuance unless a notice of appeal is filed pursuant to 10 CFR 2.740 or the Commission airects that the record be certified to it.

7. A notice or appeal of this decision or designated portsons thereof may he filed with the Commsssion, in the form required by 10 CFR . 76 (o) , within een (10) days arter service or this dactston.

. 53 -

9

4. To pursue on appeal. briers in support or the oppellant's position must also be riled, within thirty (30) days arter riling the notice of oppeal (forty days if the NRC Starr is the oppe11ont). The brier must comply 's i t h the requirements of Section 2.762.

5. Wiehin thirty (30) days (rorty days for the NRC Storr) orter the time has expired for the riling'and service or all oppe11ont briers, porties may file opposing or supporting briers that comply with the requirements or Section 2.762.

6. Filings that do not comply with the rule governing oppeals may be striken.

Respectfully submitted.

[

Susan L. Hiott l CCRE Representotsve 8075 Hunson Rd.

Hentor, OH 44060 (016) 055-3159 i

p i

e I

! APPENDIX A h- WRITTEU TESTIMONY RECEIVED INTO EVIDENCE APPLICANT 5' TESTIMONY L Following Transcript Page C179:

l

' Applicants' Direct Testimony or John C. Kommeyer on Issue No.

16*, with Statement or Qualirications or John C. Kommeyer i

' Applicants' Direct Testimony or Edward C. Christiansen on Issue No. 16*, with Statement or Qualifications or Edward C.

Christiansen

' Applicants' Direct Testimony or Charles D. Wood III on Issue fio . 16', with Statement or Quolirications or Charles D. Wood III NRC STAFF'S TESTIMONY Following Transcript Page 2281: ,

-' Joint Testimony- or Carl H..Berlinger, Drew Persinko, Spencer H.

Bush, David A. Dingee, Howard M. Hardy, Adam J. Henriksen, and B.J. Kirkwood on Issue 16 Concernsng TDI Emergency Diesel Generators at the Perry Nuclear Power planta, With Statements or

Quattrications or Said Witnesses i

I l

I I

e 4'

APPENDIX B 'a EXHIBITS IDENTIFIED AT ADMITTED AT FOLLOWINC EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT NUMBER DESCRI PTIcel PAGE PAGE PACE App. Ex. 16-l Table 8.3-1 from PNPP FSAR, 2242 2243 2243

" Connected, Automatic and Manual Loading and unloading of Engineered Safety Eva l ua t ions Fea tures_Swi tchgea r" Staff 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 Cranksha f t Indications; "SER on TDI Diesel Generator Owners Group Program Plan" Staff Ex. 2 "SER on TDI Diesel 2286 2286 2286 Gene ra tors, Perry Nuclear Power Plant, Unit I;"

Memo from C. H.

Be rl i nge r 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 ReIated Components at Shorehas leucIesr Power Station" _ _

Staff Ex. 4 Copy of a sIide presen- 2290 2290 2290 tation, " Summary of ConcIusions and Recommendations on.

Resolution of Known Problems in TDI Diesel Generator Components (Phase I of Owners Group Prog ram), Pacific Northwest Labo ra tory" ,

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-54tl, dated February 1985

(.!

,s a

4 5

IDENTIFIED AT ADMITTED AT FOLLOWING EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT NUMBER DESCRIPTION PAGE PAGE PAGE

~~~ ~~

Starr Ex. 6 "SER Related to Operation 2294 2294 2294 of Perry Nuclea r Power Plant, Units 1 and 2," dated Februa ry 1984 - NUREG-0887, Supp. No. 4 Starr Ex. 7 "SER Related to Operation 2296 L296 2296 i of Perry Nuclea r Power Plant, Units I and 2,"

dated Februa ry 1985 -

NUREG-0887, Supp. No. 5 OCRE Ex. I Gilbert / Commonwealth - 2190 2191 April 12, 1982 Letter of 2191 l T ransm i tta l and Report on Manufacturing Audit Conducted at TDI on Februa ry 23-25, 1982 OCRE Ex. 2 Executive Summa ry Summa rizing 2199 2200 2191, 2200 Status of Owners Group;

" Proposal for Closure of TDI Owners Group," from the Executive Committee Meeting of Janua ry 9, 1985; Memo to File dated -

i Janua ry 10, 1985 re Owners Group Executive Committee Meeting Minutes, Janua ry 9, 1985 OCRE Ex. 3 Letter from B. J. Youngblood 2203 2203 2203 to M. Edelman dated Ma rch 25, 1985, re confirmation of TDI Diesel Generator Pre-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 11-10 and 11-11 OCRE Ex. 5 Memo from C. L. Ray, 2212 2212 2282 Jr. to Owners Group re July 11, 1984 Meeting between NRC/PNL/0wners Group (undated)

B-2L

4 h

IDENTIFIED AT ADMITTED AT FOLLOWING EXHIBIT TRANSCRIPT TRANSCRIPT TRANSCRIPT NUMBER DESCRIPTION PACE PAGE- PAGE OCRE Ex. 6 Letter f rom 8. K. Crimes 2214 2214 2214 to M. Edelman dated Ma rch 26, 1985, re Integrated Design inspection 50-440/84-29, Supplement I, with Portion of Report Addressing Unresolved item U5.2-1, Motor Accelerating Time ___

OCRE Ex. 7 " Meta l l u rg ica l Evaluation 2226 REJECTED, 2235 of Diesel Generator Cylinder

Head Valve Seat Cracks at Grand Gulf Nuclear Station, Unit I," dated June 1984 OCRE Ex. 8 Letter f rom Boyer to NRC 2228 2229 2229 Director or Office or

• Inspection and Enforce-ment, dated Ma rch 18, 1985 OCRE Ex. 9 Copy of the deposition of 2311 REJECTED, 2313 William Foster and Carl Berl inger f rom the Shoreham proceeding, dated May 22, 1984 OCRE Ex. 10 Board Notification 84-101; 2336 REJECTED, 2338 and Excerpt of Report of Investigation into the Shoreham crankshaf t ra ilure conducted by Franklin Resea rch Center OCRE Ex. Il Cambit Newspaper article, 2397 REJECTED, 2397 no date supplied 83

1 g

n* '

i i  ::,

I CERTIFICATE OF SERVICE .

This 'is to certi'fy that copies of the foregoing were served by deposit in the U.S. Mail, first class tage prepaid, this 7 h el day of #/4 V 9k p to those on the service list b,elow. '

15 '1p 24' N0 24 2 _d gjg E OF SErm an L. Hiatt SERVICE LIST ,

1 1 I GLEASON, CHAIRMAN Terry Lodge, Esq.

• 1JANESP.RTONIC SAFETY & LICENSING BOARD 616 N. Michigan St.

1513 GILHOURE DR.MD 20901 Suite 105

5ILUER SPRING, i Toledo, OH 43624 i ,

Dr. Jerry R..Kline Atomic Safety.& Licensing Board.

Nuclehr. Regulatory Commission i U.S Wash,ington,-D.C.. 20555 ,

Mr..Glenn O.! Bright Atomic. Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Colleen P. Woodhead, Esq. -

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission ,

!.. Washington,.D.C. 20555 Jay.Silberg, Esq.

Shaw, Pittman, Potts, & Trowbridge 1800 M Street, NW

. Washington, D.C..

20036 .

+

' Docketing & Service Branch i

Offi'ce of'the Secretary U.S.. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic. Safety.& Licensing. Appeal Board Panel U.S. Nuclear Regulatory Commission -

Washington, D.C. 20555

, ,- , _ _ _ -