ML20132A529

Response Supporting Applicant 850718 Motion for Summary Disposition of Joint Intervenor Contention 14 Re Adequacy of Tdi Emergency Diesel Generators.Applicant Demonstrated Absence of Matl Fact.Affidavit of Ch Berlinger Encl

ML20132A529
Person / Time
Site:	Vogtle
Issue date:	09/23/1985
From:	Dewey L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20132A534	List: ML20132A529 ML20132A553
References
CON-#385-590 OL, NUDOCS 8509250368
Download: ML20132A529 (5)

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9/23/85

?$QE0 UNITED STATES OF AMERICA *g3 NUCLEAR REGULATORY COMMISSION 8EP37 AI di BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ifr c.-r:,$,Nf&,7,

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In the Matter of )

)

! GEORGIA POWER COMPANY ) Docket Nos. 50-424

--et al. ) 50-425

) (OL)

, (Vogtle Electric Generating Plant, )

, Units 1 and 2) )

STAFF'S RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF JOINT INTERVEN0RS' CONTENTION 14 (TDI DIESEL GENERATORS) 1 I. INTRODUCTION By Motion dated July 18, 1985, Applicants have moved, pursuant to 10 CFR 9 2.749, for suntrary disposition of Joint Intervenors' Contention la relating to the adequacy of TDI Emergency Diesel Generators (EDGs) at Vogtle. Staff supports this motion on grounds that Applicants have demonstrated the absence of any issue of material fact regarding this issue, and that they are therefore entitled to a favorable decision as a matter of law.

t In support of our response, Staff relies upon the Affidavit submitted herewith, of Carl H. Berlinger. In order to avoid unnecessary repetition, Staff's discussion in its July 26, 1985 response to Applicants' motion for summary disposition of Joint Intervenors'

) Contention 10.3 concerning the legal principles governing summary ,

dispositior is incorporated by reference herein.

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i II. BACKGROUND As admitted by the Board, Joint Intervenors' Contention 14 states that:

There is no reasonable assurance that the emergency diesel generators manufactured by TDI to be used at Plant Vogtle will provide a reliable and independent source of onsite power as required by 10 C.F.R. Part 50, Appendix A, General Design Criteria No. 17, in that adequate design, manufacture and QA/QC have resulted in substandard engines which are subject to common mode' failures.

Georgia Power Co. (Vogtle Units 1 & 2), LBP-84-35, 20 NRC 887, 911 (1984).

On July 31, 1985, Applicants moved for summary disposition of

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Contention 14 on the basis that Joint Intervenors' concerns have been assuaged by an in-depth assessment of TDI diesel generators conducted jointly by Applicants and a number of other nuclear electric utilities who also utilize these generators. Motion at 9-10. In this motion, Applicants also contended that'this joint project, referred to as the Owners Group Program, has provided specific remedies for earlier TDI defects set out by Joint Intervenors as the basis for Contention 14 (i.e., the air valve assembly, lube oil cooler assembly, piston skirts and electrical cable problems). Id. at 13-15.

III. DISCUSSION Concerns regarding the reliability of emergency diesel generators manufactured by Transamerica Delaval Incorporated (TDI) were prompted by a crankshaft failure at the Shoreham Nuclear Power Station in August 1983 and subsequent engine component failures at other plants. Berlinger Affidavit at 3. To resolve these problems, on October 25, 1983 the

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0 Applicants and twelve other U.S. nuclear utility owners formed a TDI diesel generator owners group. Their program embodied three major efforts: (1) Phase 1 - to resolve the 16 known generic problem areas identified by the Group, (2) Phase 2 - to conduct a design review / quality revalidation (DR/QR) of a large set of important engine components, and (3) identification of any needed additional engine testing or inspections i

based on Phases 1 and-2. M.at962-3. The elements of this program were subsequently assessed by Staff (See August 13, 1984 SER on TDI Diesel Generator Owners Group Program Plan), which concluded that this program incorporates the essential elements necessary to resolve

] reliability concerns for TDI diesel generators. M. at 16.

j The Owners Group has completed its generic reviews of the 16 Phase I

! generic components and submitted those reports to Staff. Id. at 17.

Staff is presently completing its review of this Phase I analysis and has preliminarily found it to be satisfactory. An evaluational report for some of these Phase I components has been issued by Staff 1/ and a report j on the remaining components is expected to be isssd this Fall. M. at i I

8.

l The Owners Group has also completed the DR/QR (Phase II Owners Group i 1 1 Report) for Vogtle. Although Staff does-not intend to perform a detailed (

i l review of this report for the Vogtle diesel engine or other non-lead l

engines at other utilities, it believes that Phase II components will be i

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-1/ This report includes Staff's evaluation of: (1) the EDG and auxiliary module wiring and terminations, (2) air start valve capscrews, (3) rocker arm capscrews, and (4) engine base and bearing caps.

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adequate at Vogtle based on its previous approval of the Owners Group DR/QR methodology and the fact that its DR/QR review of the similar Comanche Peak TDI diesel (the lead V-16 engine for the Owners Group Program) has not revealed any deficiencies. M.atQQ9,15.

Staff is also satisfied that the Vogtle TDI diesels will be reliable since Staff review of TDI diesel adequacy has been performed at Comanche Peak Unit 1, Perry, Grand Gulf Unit I and Catawba and interim SERs have been issued for those units. M.at510. Diesel reliability at Vogtle is also insured since Applicants nave committed to perform: (1) a teardown and inspection, and implementation of Owners Group Phases I and II recomnendations as were performed at Grand Gulf, Perry, Comanche Peak and Catawba, and (2) torsiograph tests, as recommended by the Owners Group, to verify crankshaf t adequacy. M.at$$13-14. In addition, it is believed that reliability will be demonstrated by a preoperational testing program for Vogtle that will detect abnormal engine behavior and is the same program which has been recommended by the Owners Group and approved by Staff. M.at116. Moreover, the Applicants have agreed to implement the Owner Group maintenance and surveillance program. M. at 517.

Based en these assurances Joint Intervenors' generalized concerns about diesel generator reliability for Vogtle are unfounded. Their specific concerns furnished as the bases for Contention 14 also appear to be resolved since the reliability of engine mounted electrical cables and the air valve assemblies have been established by Staff review of the Owners Group Phase I Report Qd. at 18 and see footnote 1, supra) and the reliability of piston skirts and governor lube oil coolers have been

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established by tests and reports done for other electric utilities utilizing similar TDI diesels. M.at65.11-12,15.

IV. CONCLUSION

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Based upon Applicants' adherente to the Owners Group Program and Applicants' above discussed commitments, there is adequate assurance that the Vogtle TDI emergency diesel generators will be reliable at the time Vogtle is licensed. Because Joint Intervenors have failed to establish any dispute as to any material fact concerning the adequacy of the Owners Group Program or the manner in which this program is to be applied to Vogtle, Applicants' motion for summary disposition of this contention should be granted.

Respectfully submitted,

^

Lee Scott Dewey Counsel for NRC Staff Dated at Bethesda, Maryland this 23rd day of September, 1985