ML20132A553
| ML20132A553 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/23/1985 |
| From: | Berlinger C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20132A534 | List: |
| References | |
| OL, NUDOCS 8509250374 | |
| Download: ML20132A553 (66) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GEORGIA POWER CO.
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Docket Nos. 50-424 et al.
50-425 (OL)
(Vogtle Electric Generating Plant, Units 1 and 2)
AFFIDAVIT OF CARL H. BERLINGER IN SUPPORT OF NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION H I, Carl H. Berlinger, being duly sworn, state as follows:
1.
I am errployed by the U.S. Nuclear Regulatory Comission and I am currently designated as the Manager of the Transamerica Delaval, Inc.
(TDI) Project Group in the Division of Licensing. A copy of my professional qualifications is enclosed as Exhibit 1.
2.
The purpose of this affidavit is to respond to the Applicant's Motion for Sumary Disposition of Contention 14, concerning the adequacy of the TDI Emergency Diesel Generators (EDGs) at Vogtle.
Joint Intervenors in this proceeding have alleged that inadequate design, manufacture, and QA/QC have resulted in substandard TDI diesel engines 8509250374 850923 i
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which prevent the Vogtle emergency diesel generators from meeting the requirements of 10CFR Part 50, Appendix A, General Design Criterion 17.
As a specific basis for this contention, the Joint Intervenors have cited past TDI diesel generator problems with the governor lube oil cooler assembly, air valve assembly, piston skirts, and engine mounted electrical cables.
3.
Concerns regarding the reliability of large bore, medium speed diesel generators manufactured by TDI for application at domestic nuclear plants 4
i were first prompted by a crankshaft failure at the Shoreham Nuclear Power Station in August 1983. However, a broad pattern of deficiencies in critical engine components have become evident at Shoreham and at other i
nuclear and non-nuclear facilities employing TDI diesel generators. These deficiencies stem from inadequacies in design, manufacture and QA/0C at TDI.
4 The NRC staff has formed a TDI Project Group to specifically address and evaluate TDI EDG problems. The staff has engaged the Battelle Pacific Ncrthwest Laboratory (PNL) as a consultant for this effort.
5.
In response to the TDI engine problems, thirteen U.S. nuclear utility owners formed a TDI diesel generator Owners Group to address reliability, operability, and quality assurance issues relative to diesel generators used for standby emergency power. Thi Owna s (roup was initiated on October 25, 1983. On March 2,1984, the Owners Group submitted their plan to the U.S. Nuclear Regulatory Commission. The Owners Group program embodies three major efforts as follows:
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Phase 1: Resolut1cr. of 10 known generic problem areas intended by i
the Owners Group to serve as a basis for the licensir.s of -plants curing the period prior to completion ard irplenentation of the i
Lwners Group prograri.
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Fhtte 7: A design review / quality revalidation (DR/QR) of a larger set of ir.portar.t tr4 ne coroponents to assure their design and j
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nonuf ac.ture.. ir.cludino specif.ications, quality ccr. trol and quality j
essurarce, ai,C crerational surveillance erd rtintenance, are j
adequate.
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iiies:tiriu, tier cf any needed additior.al engir e testing 'cr j
inspections based on firdir.gs fron Phases 1 ano E.
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A itre cetaileo description of the progrcr is given in the staff's Safety Liaination Report on the TD) D4tti Generotor Owners Group Progran Flan
'c ato i.usust 13, 1964.
In that SER, the staff concluded that the Owners l
j Grecf Program Plan incorporatet thc essential elements neecec tc resolve tbt cctstancing concerns relating to the rel.iability of the TDI diesel cererators in nuclear service. Fith the inplementation of an enharccc I
i.eintenar.ce and surveillarice picerer, the staff concluded that the TL'I diesel engines would corply with CDC 1 and GDC 17 throughout the lite of l
tiie piar,t.
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The Owners Group has.ccrrieted its generic reviews of the 16 itsse 1 Sereric ccrponents and has submitted thcst reports to the staff. The t
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applicant has corritted to follow all Phase I recommendaticns from the Owners Grcup program.
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The staff, with issisterce frcr PNL, is in the process of completing its, resitu cf the Phase 1 component analyses. To date, the staff has r
completed and issued its evtdcation of the following components:
1)
EDG and Auxilicry t'.ccule Wiring and Terminatict.s j
2)
Air Start Valve Cupscrews
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- f. otter Ana Capscrews I'
Frr4rc Bese and Bearing Caps.
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j Fel.trti i cr.c i abcve (Enclosures i and 2) t.dtress the Joint Intervenors' i
specific concerns about the relictility of the air start valve assemblics 1
I cic the engine mounted electrical ctbles, and resolve these issues.
1 1
Laelininary conclusions about the retaining Phese I items have been r.iade ba Fhl ar.o were presented at-air Ouners Orcup meeting with the stoff_on Fe t rua ry 11; 1985. These prelirirery results were favorable. The stsff i'
exiccLs tc issue e report on all of the Fhese I components this fall, enc this fir,al report will confirr the. staff's belief that these conponents erc satistectory for their intendcd purpcse.
9.
The Owr.crs Group has completed the Ch/(R (Phase II Owners Group Report) for Vogtle. The applictr,t shtaaitted the Vogtle DR/(R report tc the st.aff er Jer.uary 10, 1985. The Vogtle DR/(k is besed on the Comanche Peak l
DR/0R using Comanche Peak Unit 1 es the " lead" engine in the V-16 i
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. i catescry. lhe Comanche Peak and Vogtie engines are similar V-16 units.
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By letter dated April 26,1985,the applicant committed to implement the recorrendaticns f rom the DR/QR.
It has takcr exceptions to two of the reconnendations pertairir5 to the addition of a Dresser coupling on the s
er.giae--cr iver. lube oil pump suction line, end the replacement of certain l
slip-on joints on the'eybeest ranifolds with slip-on flanges. These o:ceptiu.s 6re not significant, but the sicff vill review and evaluate
+ hem to ensure that they de ret 6dverself affect EDG reliability. Staff cenmitun. Fht has corr.pleted but has nct ferrally issued-its final evaluation of the DP/QR prograns at Comanche Peak Unit 1 ar.d Shorehen.
1 The rcvict ci the Lca,ar.che Peak Unit 1 DR/QR has r.ot reveeled any precrrrritic deficien'cies. All suggestia.s and recortnendations identified in the Pr 1./st&fi Fhase II reports for Shorehcn and Ceranche Peek will tc rciched tu the satisfacticr. ci thc staff upon finalization of these reports.
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' 10. Vcpit, Ferry, Comanche Peak Unit 1, Grard Gulf Unit 1, and Catawba all j
have DSRV-16-4 engines. TICy (0nsist of 16 Cylinders arranged ir. C
" vee." Tht. statt has performed reviews of EOG edecuacy for Conanche Peak I
linit 1, Perry (in NUREG-08E7, Supplement No. 6, Section S.t.3.1, dated i
Apr':, ME), Grano Gulf Unit 1(in NUF,EG-CE?), Supplement No. 6, Section 8.3.1, dated August.1984) erd Catawbo(in NUREG-0954, Suppler.iu.t 4, Sect.cn 6.S.1.1, December,1964) and has issued interim SERs for each.
The SERs were " interim" ir that they were issued prior to completion of the entire Owners Group Program and _ sta'f rcvin: of Owners Group findings. The staff SER on the Owners Group Prograrn Ficn dated August 7
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. 13, 1984, specified corsiccretiuns which must be adoresse6 by individual utility owrius reciuesting a full power license prior to completing the Owners Group Prograrr art trict to coupletion of staf f review and approval of Owners Orcup finoings.
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- 11. The plant-s cific SERs already issued by the steff for all of the above nained plents accressed the ections taken by the applicants to implement the s ectrrcrotiens and conclusions put forth by the (,wners Group and the staff. These actions included the replacement of parts es t. rcLult of Fhee : trd rFtsc II corrponent inspections, dcsign nrcoltications, precperatict.ci testing, and proposed maintenance and surveillance progear s.
'hte s+.cf f SFR on the Owners Group Prograu Pibn (August 13,1984) reflected the infornisticn tvailable at that time and identifice ccr.cerns i
l regarcir,r; tte ecceptability of AE piston skirts at operating engine loads greater than those ccrrespccding to a brake mean effective pressute
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In addition, at that tire sche concerns regarding crankshaft design acequht) kcre identified. However,'the staff concluded tW. tic IEF rsip BMEP load restriction wecic be suf ficiently coaservative curing the " interim" period while those ccnccros w re being evaluated. Therefere, each of the staff SERs notec above restricted EDG-loads to limit engine Bl!EP to a naxinum of 185 psig. This ccrresponds to
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an engine ticctrical cutput of 5740.kW.
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- 12. Subsequent to in.p(. sing the engine load restricticns (due to AE piston concerns), crrrativo experience obtained treu both the TDI R-5 engine J
tests and from the Shorehani ECG-103 confire.atory "qualifice" load testing led Pt.L tr.c tFe staff to conclude that AE pistons skirts (which are j
installed at Vogtit; are edequate for service at the full design rating of EE5 psic EfEF. This corresponds to an engine electrical output of 7000 kW. The stati Will renove the 185 psig BMEP limitation with the publicatiori of its rhtsc l' final report to be issued this fcil. The Haac 1 tii'c1 report will also resolve the concerns nentioneo above i
i r(soroing the crankshaf t desigr: rdecuacy, and will present the bascs for i
l operating the V-16 errirt! tt their f ull design rating.
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- 13. Ccicister t with the actions token at Grtr.d Gulf. Perry, Conanche Peak, at:d Catawba, the applicarts htse coroitted to perform the majcr actions l
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j the steit ccr.siders necessary for licent r.g.
These actions consist of a l
i Iterdchn and inspection (now cerriettd at Vogtle), and implementaticr. of i
Critrs Group Phase I and Phase'll rect.rrcrdations including the inplenentation of an erberecc r.aintenance and surveillance progren, i),
14 In (Loittcr., consistent with the requirements established by the steff
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4 during the Grand Gulf, Perry. Catawba, and Comanche Peak reviews, the appliccr,ts have' committed to 'perforn torsiooraph tests on the Vogtle engines as recommended by the Owr 4rs Group. These tests will ccr. tina the t
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t cdequacy of both Unit I cranksbefts. The staff will review the results j.
cf iliese tests.
- 15. Although the staff will ret perform a detailed review of the Vogtle DR/QR I
l report, cr any other DR/QR reports for non "lerd" cngities, the staf f
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l believes that the Curers Group program plan which will be followed by the t
applicants provices the requisite assurance of the relitbility of the TDI l
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EDGs tc perforr; their intended function. Because of the similarity between the Vcstle and Ccmanche Peak diesels, and the degrce of reliance of Vogtle on the Ccranche Peak DR/QR report, the stcff belieses, based on its Comanche Feak revicu, that no open items of sufficient concern would be identific6 5.tich kculd reauire resoluticn prior to licensirg.
l The staff belleges that ne substantive concerns about the governor lube i'
oii coolers rerzir., tesed on the similarity o# thc Vcgtle ano Comanche Peak engu.es, and the preliminary results of the Conanche Peak DR/QR review. The sthff will cerfirm this Delief prinr to the lictnsing of Vogtl e.
16.
The staff Leliever that the applicants' precpcrational testing progran for Vogtle will be edequate to demonstrate engine crertbility by 1
detectitig Eny cbr.ormal engine behavior during the tests, lhe applicants have proposec to perfcrn oil tests recommended by the Ovr.ers Group. The staff approvcd the Owrers Group tes't progran in its 1.L9ust 13, 1964 Program Plan SER.
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- 17. Ttt trplicants have agreed to implement the naintenance and surveillance l
recommendations of the Ct.ners Group, with minor exceptions not here ee rmer.r. The Cuners Group maintenance 6nd surveillance plan, as amended by Comanche Peak in a letter irorn J. Gecrge of Texas Utilities Cererating Corrary dated June 27, 1985 (TXX-4501), will bc ccnfirmed this fall to be acceptable for generic 6pplic6 tion to all V-16 engines, ircludino 4
Voctic, fcr tht life of the plant. Since the n.ainter.arce and surveillance plan for Vogtle will be ir..pler.entea consistent with a staff-crrreved i
generic plen for all V-1C engines, we believe thct en adequate maintenance and surveillance plen will be in effect at Vogtle prior to licensing.
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- 18. The staff tistgrees with the conclusions set torth in Joint Intervenors' Contention 14. The sitif believes that the Vogtle TDI cr.gires will be relieble et tt( tirae Vogtle is licensec, based or :
- 1) the Cwners Group Progran tn resolve relichiitty issues on the TD1 engines, 2) staff review cf tFr tctc,u.cy of certain Phase 1 componer;ts, 3) the Phase 2 DR/QR review cnnducted for Cenencl.t Peak Unit 1 and the similarity cf the Vcttle (.iedeis to those at Comanche Peak, 4) previous staff conclusions er sirilar engines at Comanche Peak, Perry, Grand Gulf and Catsubt. E) p eliuinary findings by Phl on the renoinder of the Phase 1 generic corrererts, 6) the commitnent by the epplic6nts to implement a r.uintenance/surveilicnce progran at Vogtle recommended by the (wr.ers t
Group v.Fich vill be reviewed by the staff, 7) precperational testing at Vogtle to be ctrcucted as prcposed by the applicants, and 6) the dpplicants' corritrfrt to perform a t'orsiograph~ test anc subn.it the
. I results'to thc staff fcr approval.
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M Carl H. Berlinger Subscrittic ar.c swen. to tefere ne this ' 4Wday of September,1985 M
liotary Public My cu.oission expires: 7/s / F6 i
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Professional Oualifications of Carl H. Berlinger Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission My name is Carl H. Berlinger, I am the Group Manager of the TDI Project Group.
In.this position I manage the activities of the Project Group staff and ccordinate the efforts of flRR and other offices, interface with industry and licensees and as appropriate keep the ACRS, hearing boards and the Connission informed regarding the status and resolution of this issue.
I have held this
-position since January 16, 1984 I received a Ph.D in Mechnical Engineering from the University of Connecticut in 1971, and a Bachelor of Science and a Master of Science degrees in Pechanical Engineering from Clarkson College of. Technology in 1960 and 1962, respectively.
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Detailed Experience Record Carl H. Berlinger Septerber 1981 UNITED STATES NUCLEAR REGULATORY COPMISSION to January 1984 Division of Systems Integration - Core Perfornance Branch Branch Chief -
Duties included:
1.
Managenent of the activities of a branch engaged in the review, analysis and evaluation of calculational methods used by applicerts for the licensing of nuclear power plar+s in the fuel and core desian areas of reactor plant encineer-ing.
2.
Responsible for development and aoplication, in conjunction with censultants, of indeperdrnt calculational methods including corplex computer codes for the analysis of fuel anc reactor core performance during steady-state, transient, ard accident conditions.
3.
Participates as a technical specialist on various NRC connittees, subconnittees, panels, task force assignments, and on technical, industrial and professional society connittees.
d.
Represents the Connission in-dealings with other covernrental departnents and agencies, national laboratories, industry and industry creaniza-tiens in discussion of corplex technical matters in the cceas of new or proposed reactor systens.
Fovember 1980 USNRC to Septerber 1981 Division of Licensino - Systematic Eveluation Drogran Branch Section Leader - Systens Engineering Duties included:
1 Supervised senior technical staff in the Systens Ergineering section.
2.
Responsible for the analysis, evaluation erd safety reviews in the areas of thernal hydraulics, physics, site hazards, and sa'ety enalyses aspects of the reactor core, primary and secondary plant systens, electrical and I
auxiliary systens.
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. January 1980 USNRC to November 1980 Division of Licensino - Operatino Experience Evaluation Franch Branch Chief -
Duties included:
1.
Organized newly formed branch; fornulated goa's and objectives.
2.
Established procedures and_sionificance criteria #0r systematic scraening and technical -review of domestic and fore 4cr licensee event reports and operating experience reports, respectively.
3.
Initiated staff reviews of significant. licensee events.
4 Developed licensee' event reporting recuirenents.
5.
Managed and participated in the investigation of plant operatino problems and identified peneric reactor operating problens.
April 1976 USNRC to January 1980 Division of Operatino Reactors - Reactor Fafety-Branch Section Leader -
Duties included:
1.
Provided technical supervision and review of senior technical staff in the Reactor Safety Branch.
2.
Planned, coordinated and reviewed safety design evaluations of reactor cores, reactor systems, and engineerined safety features, and in accident analysis evaluations.
3.
Acted as contract coordinator.
A.
Served on the initial on-site response tean sent to TMI.
. 5.
Served as the team leader of the on-site response team sent to Oyster Creek following the 1979 plant transient.
6.
Served as a reactor systens expert detailed to the Office of the Executive Director.
September 1973 USNRC (AEC) to April 1976 Division of Operatino Reactors - Reactor Systens Branch Senior Nuclear Engineer - Reactor Systems Section Duties included:
1.
Served as a senior reactor systems specialist.
2.
Responsible for analyzing and evaluatino proposed nuclear reactor designs in the areas of thermal hydraulics, nuclear and reactor system performance.
3.
Represented the AEC before ACRS, licensee and industry meetings.
4 Responsible for making technical reconnendatiens and formulatina technical positions recarding standards, regulatory guides end codes as related to reactor safety.
August 1970 COMBUSTION ENGINEERING CORPORATION to Septenber 1973 Nuclear Power Division - Accident Analvsis Depa rtnent Principal Safety Enaineer -
Duties included:
1.
Responsible for the development of analytical tools for analysis of LfiFBR maxirum hypothetical accidents.
2.
Perforned quality assurance of corplex computer ccdes and plant safety analysis (includino LOCA and plant transients).
3.
Presented testfrony before ACRS regarding the San Onofre Units 2 and 3 plants.
4 4
Developed a transient stean generator / super-heater model for the once throuah steam generator with integral economizer.
February 1969 Uff!VERSITY OF CONNECTICUT to August 1970 Mechanical Enoineerina Department Graduate Teaching Assistant -
Duties included:
1.
Taught dndergraduate heat transfer course.
2.
Designed, procurred, constructed and operated all equipment and instrumentation reouired for Ph.D dissertation.
3.
Administered a research budget of S20,000, i
August 1961 PRATT AND WHITNEY AIRCPAFT to.
February 1969 Advanced Power Systems -
Senior Analytical Engineer -
Duties included:
1 Planning and coordinating research erd development of advance encineering products.
I 2.
Analyzea heat transfer, thermodynanic and aern-dynanic problems.
3.
Supervised the design, manufacture, testirp and evaluation of new design concepts.
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[gs# K8cg[0, UNITED STATES y
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NUCLEAR REGULATORY COMMISSION June 25, 1985 Docket Nos.: 50-322/416-417/206/312/458-459/400-401/413-414/440-441 50-438-439/445-446/424-425/329-330/460 Mr. J. B. George, Chairman Transamerica Delaval, Inc.
Owners Group Texas Utilities Generating Company Post Office Box 1002 Glen Rose, Texas 76043
Dear Mr. George:
SUBJECT:
SAFETY EVALUATION REPORT, TRANSAMERICA DELAVAL, INC.
DIESEL GENERATOR OWNERS GROUP ANALYSIS OF THE R-4 AND RV-4 SERIES EMERGENCY DIESEL GENERATOR ENGINE AND AUXILIARY MODULE WIRING AND TERMINATIONS Enclosed is the staff's evaluation of the Owners Group analysis of the Engine and Auxiliary Module Wiring and Tenninations being used by the Transamerica Delaval, Inc. on the Series R-4 and RV-4 diesel engines.
The staff found that wiring and termination at the plants listed below are adequately designed for their intended use:
Comanche Peak Steam Electric Station Unit 1 Grand Gulf Nuclear Station Unit 1 Perry Nuclear Power Plant Unit 1 Rancho Seco Nuclear Power Station Unit 1 River Bend Nuclear Power Station Unit 1 San Onofre Nuclear Generating Station Unit 1, Engine No I and 2 Shearon Harris Nuclear Power Plant Unit 1 Shoreham Nuclear Power Station Also, the staff found that wiring and teminations at Catawba and Midland were adequately designed for their intended use subject to the following actions being completed:
1.
Catawba The period of manufacture of States-Type NT sliding link teminal a.
blocks should be verified in accordance with NRC IE Information Notice No. 80-08 of March 7, 1980.
Mr. J. B. George b.
Certain Kyner-insulated, 14 AWG wire should be replaced with wire qualified to IEEE-383-1974.
2.
Midland Construction on the Midland Plant was suspended, but if it resumes, TDT SIM 361 should be implemented and the period of manufacture of States-Type link teminal blocks should be verified.
The Owners Group did not address the wiring and teminations for Vngtle-1, Bellefonte-1, and WNP-1 as part of their Phase I reports.
Instead, these itens were to be addressed during the plant-specific Phase II (DR/OR) reviews. The Owners Group, which has completed all of the DR/QR reviews, has used the same
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approach to verify the adequacy of the wiring and terminations for these three plants. On that basis, the staff finds that the wiring and terminations at Vogtle-1, Bellefonte-1, and WNP-1 are adequately designed for their intended use, provided that the licensee implements the Owners Group recomendations reached in the DR/QR reports issued by the Owners Group for these plants. Any exceptions to the Owners Group reconnendations will have to be submitted by the licensee to the NRC for review.
Hug
. Thompson, J.,
r ctor Division of Licens ng
Enclosure:
As stated CC W/ enclosure:
C. Ray, TDI l
SAFETY EVALUATION REPORT (SER)
TRANSAMERICA DELAVAL INC. (TDI) DIESEL GENERATOR OWNERS GROUP ANALYSIS OF THE R-4 AND RV-4 SERIES EMERGENCY DIESEL GENERATDR ENGINE AND AUXILLARY MODULE WIRING AND TERMINATION Introduction and Backaround Concerns regarding the reliability of large bore, medium speed diesal generators of the type supplied by Transamerica Delaval, Inc. (TDI) at 16 domestic nuclear plants were first prompted by a crankshaft failure at Shoreham in August 1983. However, a broad pattern of deficiencies in critical engine components later became evident at Shoreham, Grand Gulf Unit 1, and at other nuclear and non-nuclear facilities employing TDI diesel generators. These deficiencies sten from inadequacies in design, manufac-ture and QA/0C by TDI.
In response to these problems,13 U.S. nuclear utility owners formed a TDI Diesel Generator Owners Group to address operational and regulatory issues relative to diesel generator sets used to provide standby emergency power.
The Owners Group program, which was initiated in October 1983, embodies three major efforts:
1.
Resolution of 16 known generic problem areas (Phase I programl;
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Design review of important engine components and quality revalidation of important attributes for selected engine components (Phase II program); and
3.
Identificatinn of any needed additional engine testing or inspections, based on findings stemming from the Phase I and IT programs.
The Owners Group program plan, submitted on March 2,1984, was ~ reviewed by the U.S. Nuclear Regulatory Commission (NRC) in a Safety Evaluation Report (SER) on August 13, 1984 The Owners Group has performed design analysis and considered surveillance requirements for the 16 coeponents in Phase I to ascertain whether their
~ design would be acceptable for application 50 specific engine designs.
The components are as follows: Air Start Valve Capscrews, Connecting Rods, Connecting Rod Bearing Shells, Crankshaft, Cylinder Block, Cylinder Heads, Cylinder Head Studs, Cylinder Liner, Engine Base and Bearing Caps, Engine Mounted Electrical Cable, High Pressure Fuel Oil Tubing, Jacket Water Pumps, Piston Skirts, Push Rods, Rocker Arm Capscrews and Turbochargers. The engines considered were the DSR-48 (in-line 8), DSRV-12, DSRV-16, a nd DSRV-20 The wiring and terminations reviewed in this SER apply to the following plants:
Catawba Nuclear Station Unit 1, Comanche Peak Steam Electric Station Unit 1, Grand Gulf Nuclear Station Unit 1 Midland Nuclear Power Plant, Perry Nuclear Power Plant Unit 1, Rancho Seco Nuclear Power Station Unit 1, River Bend Nuclear Power Station Unit 1, San Onofre Nuclear Generating Station Unit 1 Engine No. I and 2, Shearon Harris Nuclear Power Plant Unit 1, Shoreham Nuclear Power Station, Vogtle-1, Bellefonte-1, and WNP-1.
Phase I reports on wiring and terminations were issued by the Owners Group for all' but the last 3 plants, i.e., Vogtle-1, Bellefonte-1, and WNP-1. The latter three were reviewed by the Owners Group to the same criteria as the former 10, but specific Phase I reports were not developed; the results of the review were included in the Phase II DR/QR reports because of the plant specific nature of this component and because Phase II reports were being developed at the time.
Evaluation The enclosure to this SER is a Technical Evaluation Report (TER), entitled
" Review of Emergency Diesel Generator Engine and Auxiliary Module Wiring and Terminations." This TER was prepared by Pacific Northwest Laboratory (PNL) which is under contract to the NRC to perform technical evaluations of the T]I Owners Group generic program, in addition to plant-specific evaluations relating to the reliability of TDI diesels. PNL has retained the services of several expert diesel consultants as part of its review staff.
The staff, PNL and its consultants reviewed the Owners Group submittals listed in the references and have performed onsite inspections of the wirir.g and tenninations at several nuclear plants. The staff has reviewed the enclosed TER, and adopts the TER as part of this safety evaluation by reference.
The Stone and Webster Engineering Company (SWEC), a consultant to the Owners Group, performed a survey at each of the plants listed previously to review the following:
t
-4 Identify all wiring and terminations supp'ied with the diesel engines from TDI manuals (or, in the case of Shorehe from SWEC design documents).
3 Review the wiring insulation for compatibility with circuit requirements.
Determine if the insulating material is known to have generic fire-retardant characteristics and is qualified to selected industry standards.
Review the wiring installation routing to determine the physical environment for each cable.
Evaluate circuit requirenents to determine if special cable is required.
Compare the termination types, materials, sizes, and insulation ratings as given in the manufacturer's specifications with the characteristics required for the particular circuit and environment.
The SWEC survey found that most plants had wiring and terminations that were properly rated. Some of the installations were deficient and SWEC recommended that wiring be replaced and that certain terminations be verified. The specific plant deficiencies in the first 10 plants are summarized in Section 2.2 of the PNL TER. Recommendations with regard to the other 3 plants are in the individual DR/QR reports for Vogtle-1, Bellefonte-1, and WNP-1.
The staff and PNL concur in the approach used to evaluate the class IE auxiliary I
module wiring and terminations currently installed on TDI diesel generators at the nuclear power plants reviewed.
. Conclusions As a result of the review performed by the Owners Group and PNL and upgrades put in place by the licensee, the staff finds that the wiring and terminations at the plants listed below are adequately designed for their intended use:
Comanche Peak Steam Electric Station Unit I Grand Gulf Nuclear Station Unit 1 Perry Nuclear Power Plant Unit 1 Rancho Seco Nuclear Power Station Unit 1 River Bend Nuclear Power Station Unit 1 San Onofre Nuclear Generating Station Unit 1, Engine No. I and 2 Shearon Harris Nuclear Power-Plant Unit 1 Shoreham Nuclear Power Station Also, the staff found that wiring and terminations at Catawba and Midland were adequately designed for their intended use subject to the following actions being completed:
1.
Catawba The period of manufacture of. States-type NT sliding link terminal a.
blocks should be verified in accordance with NRC IE Information flotice No. 80-08 of March 7,1980.
b.
Certain Kyner-insulated,14 AWG wire should be replaced with wire qualified to IEEE-383-1974.
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Midland Construction on the Midland Plant was suspended but if it resumes, TDI SIM 361 should be implemented and the period of manufacture of Stater-Type link teminal blocks should be verified.
The Owners Group did not address the wiring and terminations for Vogtle-1, Bellefonte-1, and WNP-1 as part of their Phase I reports.
Instead, these items were to be addressed during the plant specific Phase II (DR/0R) reviews.
The-Owners Group, which has completed all of the DR/QR reviews, has used the same approach to verify the adequacy of the wiring and terminations for these three plants.
On that basis, the staff finds that the wiring and terminations at Vogtle-1, Bellefonte-1, and WNP-1 are adequately designed for their intended use provided that the ifcensee irtplements the Owners Group recommendations reached in the DR/QR reports issued by the Owners Group for these plants.
Any exceptions to the Owners Group recommendations will have to be submitted by the ifcensee to the NRC for review.
REFERENCES 1.
Letter, D. G. Eisenhut (NRC) to J. B. George (TUGCo), " Safety Evaluation Report, Transamerica Delaval, Inc., Diesel Generator Owners Gro.rp Program Plan" dated August 13, 1984.
2.
Battelle Pacific Northwest Laboratory May 1985 Technical Evaluation Report,
" Review of Emergency Diesel Generator Engine and Auxiliary Module Wiring and Teminations," PNL-5200-3.
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Emerf.ency Diesel Generator F
Engine and Auxiliary Module Wiring and Terminations sw-u May 1985 E-Prepared for ~
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the U.S. Nuclear Itegidatory Commission Division of Ucensing Office of Nuclear Reactor Regulation u'nder Contract DE-AC26-76RLO 1830 NRC HN B2952.
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PNL-5200-3 9
Technical Evaluation Report REVIEW OF EMERGENCY DIESEL GEN'ERATOR ENGINE AND AUXILIARY-MODULE WIRING AND TERMINATIONS l
May 1985 i
Prepared for the U.S. Nuclear Regulatory Commission Division of Licensing i
Office of Nuclear Reactor Regulation under Contract DE-AC06-76RLO 1830 NRC FIN B2952 Project
Title:
Assessment of Diesel Engine Reliability / Operability NRC Lead Engineer:
C. H. Berlinger Pacific Northwest Laboratory Richland, Washington 99352 i
L
FOREWORD This report is supplied as part of the Technical Assistance Project, Assessment of Diesel Engine Reliability / Operability, being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Licensing, by the Pacific Northwest Laboratory.
4 The U.S. Nuclear Regulatory Commission funded this work under authorization BAR20-19-40-42-1 FIN Ho. B2952.
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PACIFIC NORTHWEST LABORATORY PROJECT APPROVALS D-Date M~
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W. W. Laity. Project Manager Pacific Northwest Laboratory [
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Date
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W. D. Richmond, Chairman Senior Review Panel Pacific Northwest Laboratory i
111 1
- - - - - ~
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ACKNOWLEDGMENTS This report was compiled by PNL project team members J. F. Nesbitt and F. R. Zaloudek based on technical contributions provided by PNL staff member C. L. Wilson and consultants E. Loftus, P. J. Louzecky, W. R. McSpadden, J. E. Horner, and N. M. Rivera.
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ABSTRACT This report documents the review performed by the Pacific Northwest Laboratory (PNL) of action taken by the Transamerica Delaval, Inc. (TDI) Diesel Generator Dwners' Group to evaluate wiring and terminations for TDI engines at 10 nuclear power plants.
In response to TDI Service Information Memo (SIM) 361, Rev.1, concerning potentially defective engine-mounted cables for the Woodward governor / actuator and the Air-Pax magnetic pickup, the Owners' Group authorized Stone & Webster Engineering Corporation (SWEC) to evaluate all class IE auxiliary module wiring and terminations installed on the engines.
The evaluations are described in five SWEC reports.
In field surveys of the engine installations, SWEC investigated the compatibility of the wiring and terminations on the diesel engines with the electrical and environmental service characteristics of the applications. SWEC conclusions and recommendations are as follows:
The existing wiring and terminations are acceptable for service at e
the following installations:
Comanche Peak Grand Gulf Perry Rancho Seco River Bend San Onofre Engine No. 2 Shearon Harris The following recommendations should be implemented at the e
installations noted:
Catawba:
TDI SIM 361 should be implemented, the period of manufacture of the States-type sliding link terminal blocks should be verified, and certain Kyner-insulated wire should be repl aced. -
v
Midland: TDI SIM 361 should be implemented, and the period of manufacture of the States-type sliding link terminal blocks should be verified.
(Construction of this power plant was subsequently suspended.)
San Onofre Engine No. 1: TDI SIM 361 shculd be implemented.
Shoreham: Wiring with type MTW insulation should be replaced in the circuits for the crankcase vacuum fans and the starting air supply solenoid valves.
PNL concurs with the conclusions and recommendations described in the SWEC reports.
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CONTENTS FOREWORD.................................................................
11 PACIFIC NORTHWEST L ABOR ATORY PROJECT APPROVALS...................
ill A C KN O WL E DGME N T S.................................................
iv ABSTRACT.................................................................
v
1.0 INTRODUCTION
1 1.1 ISSUE ADDRESSED BY OWNERS' GROUP...............................
2
1.2 DESCRIPTION
OF INSTALLATIONS...................................
2 2.0 OWNERS' GROUP STUDY.................................................
2 2.1 SCOPE OF INVESTIGATION.........................................
3 2.2
SUMMARY
OF RESULTS.............................................
3 2.2.1 Shoreh'am Nucl ea r Power Station..........................
3 2.2.2 Comanche Peak Steam Electric Station Unit 1.............
4 2.2.3 Grand Gul f Nucl ea r Station Uni t 1.......................4 2.2.4 Catawba Nuclear Station Unit 1..........................
4 2.2.5 Other Nucl ea r Power Stations............................5 2.3 REVIEWS DEFERRED TO PHASE II 0F OWNERS' GROUP PROGRAM..........
6 3.0 PNL'S EVALUATION....................................................
6
4.0 CONCLUSION
S AND RECOMMENDATIONS...................................
7 4.1 INSTALLATIONS FOR WHICH NO FURTHER ACTION IS NECESSARY.........
7 4.2 INSTALL ATIONS RECOMMENDED FOR FURTHER ACTION.................
8 4.2.1 Ac t i o n Compl e te d........................................
8 4.2.2 Action Pending..........................................
8 4.2.3 Ac t i o n De f e r re d.........................................
9 vii i
4.3 REVIEWS DEFERRED TO PHASE II 0F OWNERS' GROUP PROGRAM..........
9
. REFERENCES...............................................................
10 t
l viii l
I
REVIEW OF EMERGENCY DIESEL GENERATOR ENGINE AND AUXILIARY MODULE WIRING AND TERMINATIONS
1.0 INTRODUCTION
The Pacific Northwest Laboratory (PNL) is supporting the U.S. Nuclear Regulatory Comission (NRC) staff in addressing questions of the reliability, operability, and quality assurance of Transamerica Delaval, Inc. (TDI) diesel j
enoines used to provide standby power in some nuclear power plants. These ouestions were raised because of a major failure in one TDI diesel at the
~
Shoreham Nuclear Power Station in August 1983 and other problems encountered with TDI diesels. One of the principal tasks in PNL's effort is to evaluate the resolution by the TDI Owners' Group of known problems with potential generic applicability.
This report documents PNL's evaluation of the Owners' Group review of the electrical wiring and teminations supplied with the TDI emergency diesel generators at the Catawba, Comanche Peak, Grand Gulf, Midland, Perry, Rancho Seco, River Bend, San Onofre, Shearon Harris, and Shoreham nuclear power sta-tions. The details of the Owners' Group review were presented in five reports orecared by Stone & Webster Engineering Corporation (SWEC):
Emergency Diesel Generator Engine and Auxiliary Module Wiring and l
e Temination Qualification to IEEE-383-1974, April 1984
- Supolement To The Emergency Diesel Generator Auxiliary Module Control l
Wiring and Termination Qualification Review DR4-210-013, May 4,1984 l'
Supplement to the Emergency Diesel Generator Auxiliary Module Control l
e l
Wiring and Temination Qualification Review, B2-1160060-2, June 1984 Supplement to the Emergency Diesel Generator Auxiliary Module Control e
Wiring and Temination Qualification Review, B2-1160060-4, June 1984 Emeroency Diesel Generator Auxiliary Module Control Wiring and e
Temination Qualification Review, TDIO287, July 1984.
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1 i
s 1.1 ISSUE ADDRESSED BY OWNERS' GROUP TD1's Service Information Memo (SIM) 361, Rev.1 notified the engine owners of potentially defective engine-mounted cables associated with the Woodward governor / actuator and the Air-Pax magnetic pickup. This memo led the Owners' Group to question the suitability of all class IE auxiliary module wiring and terminations currently installed on the diesel engines.
Of special interest was the suitability of this wiring with respect to flame-retardancy of the insulation, qualification to industry standards, routing of conduit, compatibility with circuit requirements, and the need for special requirements such as shielding.
1.2 DESCRIPTION
OF INSTALLATIONS All cable / wire associated with the engines is generally routed in either electrical metallic tubing (EMT), rigid galvanized steel conduit, or flexible conduit.
A variety of wire and insulation types is used, depending on the characteristics of the circuit. These include types SIS, MTW, XLPE, and XHHW.
The conduits installed on the skid and supported away from the engine are potentially subject to the maximum room temperature (120*F to 140*F).
The junction boxes, conduits, and cables attached to the engine block are poten-tially subject to at least engine cooling jacket / lubricating oil-temperature (180*F).
2.0 OWNERS' GROUP STUDY This issue was addressed by SWEC, a consultant to the Owners' Group.
The objectives of the SWEC effort were to examine the functional attributes of the electrical wiring and terminations supplied with the diesel engines and to determine their suitability for the intended purpose.
2 i
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2.1 SCOPE OF INVESTIGATION The scope of SWEC's investigation encompassed the following activities:
Identify. all wiring and terminations supplied with the diesel engines from TDI manuals (or, in the case of Shoreham, from the SWEC design documents),
Review the wiring insulation for compatibility with circuit e
reauirements.-
Determine if the insulating material is known to have generic fire-retardant characteristics and is qualified to selected industry standards.
Review the wiring installation routing to determine the physical e
environment for each cable, Evaluate circuit requirements to determine if special cable is o
reautred.
Compare the termination types, materials, sizes, and insulation ratings as given in the manufacturer's specifications with the characteristics required for the particular circuit and environment.
2.2
SUMMARY
OF RESULTS 2.2.1 Shoreham Nuclear Power Station SWEC surveyed the class IE auxiliary module wiring and terminations currently installed on the TDI diesel engines at Shoreham.
Each circuit's service characteristics were identified and compared to the service ratings of the cable and termination types used.
IEEE-383-1974 was used as the basis for this review.
As reported in Emergency Diesel Generator Engine and Auxiliary Module Wiring and Termination Qualification to IEEE-383-1974 (April 1984), SWEC reached the following conclusions for the Shoreham engines:
t Qualified replacement cable was provided by TDI and installed on the e
diesel engines in accordance with SIM 361, Rev.1.
i l
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The module wiring, cable, and teminations are compatible with the e
circuit characteristics and the operating environment, except for the wiring with type MTW insulation used in the circuits for the crar.k-case vacuum fans and the starting air supply solenoid valves. Type MTW insulation is not compatible with expected ambient teitperatures in these circuits. The selected replacement cable, Okonite 1/C812-19X Black Okozel (Tefzel insulation), type ZW, rated at 125'C, is acceptable for the expected operating temperature (87.2*C). When this +'eplacement is accomplished, all functional attributes esta'elished for the design review of the wiring and teminations will be satisfied.
~
2.2.2 Comanche Peak Steam Electric Station Unit 1 Taking into consideration the same attributes and qualifications as those applied at Shoreham, SWEC conducted a field survey of the class IE auxiliary module wiring and terminations currently installed on the TDI diesel engines at Comanche Peak. SWEC reported in the Supplement to the Emergency Diesel Generator Auxiliary Module Wiring and Termination Qualification Review (May 1984) that all wiring and terminations are acceptable for their intended service.
2.2.3 Grand Gulf Nuclear Station Unit 1 In the Supplement to the Emergency Diesel Generator Auxiliary Module Control Wiring and Temination Qualification Review (B2-1160060-2, June 1984),
SWEC concluded from a field survey of the TDI diesel engines at Grand Gulf that qualified replacement cable had been installed in accordance with SIM 361, Rev.1, and that all wiring and terminations are acceptable for their intended service.-
2.2.4 Catawba Nuclear Station Unit 1 The results of the field survey conducted by SWEC on the TDI engines at~
Catawba are reported in the Supplement to the Emergency Diesel Generator j
Auxiliary Module Control Wiring and Termination Qualification Review 4
i
(P,2-1160060-4, June 1984). SWEC found the wiring and terminations accept-able for their intended service, subject to implementation of the following recommendations:
TDI SIM 361 should be implemented.
In accordance with NRC IE Information Notice No. 80-08 of March 7, 1980, the period of manufacture of States-type NT sliding link terminal blocks (item 5 in Table A of the SWEC report) should be checked to verify that the blocks were produced in a time period other than 1974 through 1976.
The Kyner-insulated,14 AWG wire i'dentified as item 2 in Table A of e
the SWEC report should be replaced with wire qualified to IEEE-383-1974 2.2.5 Other Nuclear Power Stations The results of the field surveys conducted on class IE auxiliary module wiring and terminations installed on TDI diesel engines at six other nuclear power stations were reported by SWEC in Emergency Diesel Generator Auxiliary Module Control Wiring and Termination Qualification Review (July 1984). SWEC found the existing wiring, cable, and terminations acceptable for their intended service on the TDI engines at the following installations:
Perry Nuclear Power Plant Unit 1 e
Rancho Seco Nuclear Power Station Unit 1 o
River Bend Nuclear Power Station Unit 1 e
San Onofre Nuclear Generating Station Unit 1, Engine No. 2 e
Shearon Harris Nuclear Power Plant Unit 1.
e SWEC also found the wiring and terminations acceptable for the intended service at the following installations, subject to implementation of certain l
recommendations:
Midland Nuclear Power Plant - TDI SIM 361 should be implemented, and e
the period of manufacture of the States-type sliding-link terminal blocks should be verified.
l 5
San Onofre Nuclear Generating Station Unit 1, Engine No.1 - TDI e
SIM 361 should be implemented.
2.3 REVIEWS DEFERRED TO PHASE II 0F OWNERS' GROUP PROGRAM SWEC commented in the above-mentioned report of July 1984 that wiring and tereinations on engines not reviewed during Phase I of the Owners' Group Program will be reviewed as part of the Phase II Design Review / Quality Revalidation Program.
3.0 PNL'S EVALUATION I
The following PNL staff and consultants participated in the reviews of the reports prepared by Stone & Webster Engineering Corporation on engine and auxiliary module wiring and terminations:
J. F. Nesbitt, PNL project team e
E. Loftus, electrical engineer, Kaiser Engineers Hanford Co.
P. J. Louzecky, consultant, Engineered Applications Corporation W. R. McSpadden, Ph.D., engineering consultant e
J..E. Horner, consultant, Seaworthy Systems, Inc.
e H. M. Rivera, consultant, Designers and Planners, Inc. (TRACOR Hydronautics, Inc.)
C. L. Wilson, PNL staff.
e PNL's reviews focused on the following areas:
Were the methods of analysis and approaches taken in the studies e
satisfactory?
Are the information and data collected in the ' studies adequate for e
proper evaluation?
Are the conclusions and recommendations supportable?
e Have the objectives of the study been met?
e 6
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PHL's reviews focused on the SWEC reports. Some use was made of specific references and written and oral information requested from and provided by the Owners' Group.
4.0 CONCLUSION
S AND RECOMMENDATIONS PNL concurs with the approach used to evaluate the class IE auxiliary module wiring and terminations currently installed on TDI diesel generators at 10 nuclear power plants owned by the TDI Diesel Generator Owners' Group. PNL also concurs with the conclusions and recommendations in the five SWEC reports on the field surveys of the wiring and terminations. SWEC's conclusions and recommendations, and the references for them, are discussed in Section 2.P. of this report. They are categorized under the two subheadings that follow according to those found to be satisfactory during the field surveys and those for which SWEC recommended that certain actions by taken.
4.1 INSTALLATIONS FOR WHICH NO FURTHER ACTION IS NECESSARY SWEC concluded that the existing class IE auxiliary module wiring and terminations are acceptable for service on TDI diesel engines at the instal-lations listed below. On the basis of the field surveys reported by SWEC, PNL concurs that no further action to upgrade thlengine-mounted wiring and I
terminations at these installations is necessary:
Comanche Peak Steam Electric Station Unit 1 Grand Gulf Nuclear Station Unit 1 e
Perry Nuclear Power Plant Unit 1 e
Rancho Seco Nuclear Power Station Unit 1 e
River Bend Nuclear Power Station Unit 1 e
San Onofre Nuclear Generating Station Unit 1, Engine No. 2 e
Shearon Harris Nuclear Power Plant Unit 1.
e 7
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t 4.2 INSTALLATIONS RECOMMENDED FOR FURTHER ACTION SWEC concluded that the wiring and teminations on TDI diesel engines are acceptable for service at three other 14sta11ations, subject to implementation of certain recommendations. These recommendations, and the status of action on each at the time this PNL report was written, are as follows.
4.2.1 Action Completed San Onofre Nuclear Generating Station Unit 1. Engine No.1 e
SWEC Recomendation: TDI SIM 361 should be implemented.
Status:
In a letter to NRC (C. H. Berlinger) dated April 3, 1985, the Owners' Group ( A. M. Segrest) confimed that SIM 361 has been implemented on this engine.
(TOI SIM 361 had pre-i viously been implemented on Engine No. 2.)
i i
e Shoreham Nuclear Power Station SWEC Recommendation: Wiring with type MTW insulation should be I
replaced in three circuits for the crankcase vacuum fans and the starting air supply solenoid valves. The selected replacement cable, Okonite 1/C#12-19X Black Okozel (Tefzel insulation), is acceptable for the expected operating temperature.
Status:
In a letter to NRC (C. H. Berlinger) dated May 7,1985, 3
i Duke Power Company (A. M. Segrest) confimed on behalf of the Owners' Group that this recomendation has been implemented.
4.2.2 Action Pending o Catawba Nuclear Station Unit 1 SWEC Recomendations:
l a.
TDI SIM 361 should be implemented.
b.
The period of manufacture of States-type NT sliding link teminal blocks should be verified in accordance with NRC IE Infomation Notice No. 80-08 of March 7,1980.
i 8
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Certain Kyner-insulated,14 AWG wire should be replaced with c.
wire qualified to IEEE-383-1974.
In a letter to NRC (C. H. Berlinger) dated April 3, Status:
1985 Duke Power Company-(A. M. Segrest) confirmed on behalf of the Owners' Group that SIM 361 has been implemented (recommen-dation a., above), but that the verification of the sliding ifnk terminal blocks has not been performed to date (recommendation b.). " Duke Power ( A. M. Segrest) stated in a letter to NRC (C.
^
H. Berlinger) dated May 7,1985 that the Kyner-insulated wire has not yet been replaced (reconenendation c.)
PNL Recommendation:
SWEC recommendations b. and c., above, should be implemented by Duke Power Company in a timely manner
-and no later than the first outage for power plant refueling.
4.2.3 Action Deferred Midland Nuclear Power Plant e
SWEC Recommendations: TDI SIM 361'should be implemented, and the period of manufacture of States-type link terminal blocks should be verified.
i Status:
Construction of the Midland plant was suspended, and i
the owner, Consumers Power Company, withdrew from the TDI Diesel Generator Owners' Group.
PNL Recommendation: The SWEC recommendations should be implemented if construction of the Midland plant is resumed.
'L. 3 j
4.3 REVIEWS DEFERRED TO PHASE II 0F OWNERS' GROUP PROGRAM As noted in Section 2.2.6 'of this report, SWEC observed that wiring and teminations on engines not reviewed during Phase I of the Owners' Group Program will be reviewed as part of Phase II, the Design Review / Quality Revalidation Program. PNL recomends that these later reviews be conducted t
using the same approach and with the same thoroughness as was used in the reviews already completed.
9
REFERENCES ANSI /IEEE STD 383-1974.
IEEE Standard for Ty)e Test of Class IE Electric Cables, Field Splices, and connections for liuclear Power Generating Stations.
4 i
The Institute of Electrical and Electronics Engineers, Inc., New York, New York.
i Ray, C. L., Jr. August 13, 1984. Letter to NRC (C. H. Berlinger, "TDI Diesel Generator Owners' Group Response to PNL and NRC Questions."
l Segrest, A. M.
April 3, 1985. Letter to NRC (C. H. Berlinger) re Response of TDI Owners' Group to Questions on Engine Wiring and Terminations.
Segrest, A. M.
May 7, 1985. Letter to NRC (C. H. Berlinger) re Response of' 1
TDI Owners' Group to Questions on Engine Wiring and Terminations.
1 Stone & Webster Engineering Corporation. April 1984. Emergency Diesei Generator Engine and Auxiliary Module Wiring and Termination Qualification to IEEE-383-1974. -Boston, Massachusetts.
Stone & Webster Engineering Corporation. May 1984.
Supplement To The Emergency Diesel Generator Auxiliary Module Control Wiring and Termination a
Qualification Review. DR4-210-013, Boston, Massachusetts.
I Stone & Webster Engineering Cor.: oration. June 1984. Supplement to the Emergency Diesel Generator Auxiliary Module Control Wiring and Termination Qualification Review.
B2-1160060-2, Boston, Massachusetts.
Stone & Webster Engineering Corporation. June 1984 Supplement to the Emergency Diesel Generator Auxiliary Module Control Wiring and Termination Qualification Review.
82-1160060-4, Boston, Massachusetts.
t Stone & Webster Engineering Corporation. July 1984. Emergency Diesel 4
Generator Auxiliary Module Control Wiring and Termination Qualification Review. TDIO287, Boston, Massachusetts.
4 i
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PNL-5200-3 DISTRIBUTION No. of No. of Copies Copies OFFSITE P. Lang, NE-14 U.S. Department of Energy 16 Division of Licensing Office of Nuclear Energy Office of Nuclear Reactor Washington, DC 20555 Regulation U.S. Nuclear Regulatory ONSITE Commission Washington, DC 20555 DOE Richland Operations Office ATTN:
C. Berlinger (10)
M. Carrington (2)'
H. Ransom /M. Plahuta D. Corley F. Miraglia Pacific Northwest Laboratory H. Thompson M. Williams 5 Consul tants 1
12 NRC Plant Project Managers J. Horner Division of Licensing E. Loftus U.S. Nuclear Regulatory P. Louzecky Commission W. McSpadden Washington, DC 20555 N. Rivera ATTN:
B. Buckley S. Burwell 5 Senior Review Panel D. Hood D.' Houston F. Albaugh K. Jabbour S. Bush T. Kenyon C. Hill l
E. McKenna ~
W. Richmond M. Miller L. Williams S. Miner C. Stahle 27 Project Team J. Stefano E. Weinkam l
J. Alzheimer A. Currie 2
U.S. Nuclear Regulatory D. Dingee Commission Public Document ~ Room R. Dodge W. Gintner Division of Technical W. Laity (20)
Information and Document J. Nesbitt Control F. Zaloudek Washington, DC 20555 i
Technical Information (5)
Publishing Coordination (2) i Distr-1
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[p oog'o, UNITED STATES E'
NUCLEAR REGULATORY COMMISSION r.
WASHINGTON. D. C. 20555 k.....,o,E 8
June 17,1985 Docket Nos:
50-322/416-417/206/312/458-459/400-401/413-414/440r441 50-438-439/445-446/424-425/329-330/460 t'
Mr. J.8. George, Chairman Transamerica Delavel, Inc.
Owners Group Texas Utilities Generating Company Post Office Box 1002 Glen Rose, Texas 76043
Dear Mr. George:
SUBJECT:
SAFfTY EVALUATION REPORT, TRANSAMERICA DELAVAL, INC.
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DIESEL GENERATOR OWNERS GROUP ANALYSIS OF THE R-4 AND
~
RV-4 SERIES EMERGENCY DIESEL GENERATOR AIR START VALVE CAPSCREWS
- Enclosed is the staff's evaluation of the Owners Group analysis of the Air Start Valve capscrews being used by the Transamerica Delaval, Inc. on the Series R-4 and RV-4 diesel engines.
The staff found that the shorter capscrews currently recommended are adequately designed for their intended Certain installation and maintenance requirements should be followed use.
by the owners as outlined in the evaluation of the enclosure, Sincerely, 1$11 Hug
. Thompson,
.,D ctor
~--
Div on of Licensing 7
Enclosure:
As Stated cc:
w/ enclosure C. Ray, TDI 3
O
SAFETY EVALUATION REPORT (SER)
TRANSAMERICA DELAVAL INC. (TDI) DIESEL GENERATOR OWNERS GROUP ANALYSIS OF THE R-4 AND RV-4 SERIES EMERGENCY DIESEL GENERATOR AIR START VALVE CAPSCREWS INTRODUCTION AND BACKGROUND
{
Concerns regarding the reliability of large bore, medium speed diesel generators of the type supplied by Transamerica Delaval, Inc. (TDI) at 16 domestic nuclear plants were first prompted by a crankshaft failure at Shoreham in August 1983.
However, a broad pattern of deficiencies in
- - ceitical engine components later became evident at Shoreham, Grand Gulf '
a - - ---
Unit I a~nd at other nuclear and non-nuclear facilities employing TOI
, diesel generators.
These deficiencies stem from inadequacies in design, manufacture, and QA/QC by TDI.
In response to these problems, 13 U.S. nuclear utility owners formed a TDI Diesel Generator Owners Group to address operational and regulatory b-issues relative to diesel generator sets used to provide standby emergency power.
The Owners Group program, which was initiated in October 1983, i
embodies three major efforts:
1.
Resolution of 16 known generic problem areas (Phase I program);
2.
design review of important engine components and quality revalidation of important attributes for selected engine components (Phase II program); and 9
3.
identification of any needed additional engine testing or,
inspections,basedonfindingsstemmingfromthePhaskIand11 programs.
The Owners Group program plan, submitted on March 2, 1984, was' reviewed by the U.S. Nuclear Regulatory Commission (NRC) in a Safety Evaluation Report (SER) on August 13, 1984.
w.
~.
k The Owners Group has performed design analysis and considered surveillance
- requirements for the.16 components in Phase I to ascertain whether their l-design would be acceptable for application to specific engine designs.
-5
'The components are as follows:
Air Start Valve Capscrews, Connecting Rods,
Connecting Rod Bearing Shells, Crankshaft, Cylinder Block, Cylinder Heads, Cylinder Head Studs, Cylinder Liner, Engine Base and Bearing Caps, Engine
~~
Mounted Electrical Cable, High Pressure Fuel Oil Tubing, Jacket Water Pumps, Piston Skirts, Push Rods, Rocker Arm Capscrews and Turbochargers.
The engines considered were the DSR-48 (in-line 8), DSRV-12, DSRV-16, and DSRV-20.
l The Air Start Valve capscrews reviewed in this SER are applicable to all four engine configurations.
i
.,. _,. _ _ _ _... _ -, ~. _ _, _. _ _. _.
, EVALUATION b
The enclosure to this SER is a Technical Evaluation Report (TER) entitled
" Review of Emergency Diesel Generator Air Start Valve capscrews." This TER was prepared by Pacific Northwest Laboratory (PNL) which is under contract to the NRC to perform technical evaluations of the TDI Owners Group generic program, in addition to plant-specific evaluations relating to the reli-atrility of TDI diesels.
PNL has retained the services of several expert 6--
~
diesel consultants as part of its review staff.
The staff, PNL and its consultants reviewed the Owners Group submittals listed in the references and have performed onsite inspections of this component at several nuclear plants.
The staff has reviewed the enclosed TER, and adopts the TER as part of this safety evaluation by reference.
h-The Owners Group reviewed the Air Start Valve capscrew designs.
The static strength and endurance strength have adequate margins over the static stress and cyclic stress.
The shortened air start valve capscrews are fabricated from SAE grade 5 (min) material.
Stone and Webster performed further analyses and provided information to the Owners Group which forms the basis for the PNL
-review.
PNL determined that the analytical methods used by Stone & We.bsher were is consistent with standard engineering practice and were appropriitely applied.
All assumptions used in the analysis were found to be conservative.
The Stone & Webster analysis indicated that 1) the new 2-3/4-inch capscrews would not bottom out, 2) their maximum stress is well below the yield stress, and 3) they are not subject to fatigue failure if installed with the specified preload.
PNL concurred with these w. -......
conclusions, provided that 1) there is sufficient assurance that the capscrews installed have the proper length and 2) the preload on the
~ capscrews is properly established and maintained.
The concern with the preload is that the copper gasket used in the installation of the air start valve would creep under the sustained loading from.the capscrews, resulting in a diminution of the preload.
Both these issues were addressed and it was recommended (1) that the capscrew length be measured, on a sample basis, as a part of DR/QR effort for each plant and 2) that an installation procedure be developed to ensure that the proper preload was imposed on the
- [-
capscrews.
The procedure as developed calls for the initial installation of these capscrews with 150 ft-lb torque followed by retorquing every 8 h w s until no further change is noted in the terqua PN!. concurs vHf :'r procedure; however, PNL recommends that the torque on these capscrews be checked following the first period of engine operation after a new gasket isinstalled,toensurethatnoadditionalgasketcreepoccurs(saresult of the additional thermal and mechanical stresses.
Inpreviousplantspecific I
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TERs, PNL had recommended that a 100% preload check of the air s, tart valve capscrews be performed at every refueling outage.
The PNL conchsions in this TER regarding maintenance and surveillance reflect additional informa-tion presented by the Owners Group at a meeting held on February 11, 1985 (transcript available) and supersedes PNL's earlie' recommendation.
r CONCLUSIONS w..-
~
The staff has reviewed the PNL Technical Evaluation Report, " Review of
. Emergency Diesel Generator Air Start Valve Capscrews" and is in agreement with the conclusions presented.
On the basis of the review of the referenced documents and calculations provided by the TOI Owners Group, the staff concurs with PNL's conclusion a'-
that the described design for the air start valve capscrew is acceptable for the intended service.
This conclusion assumes that 1) a sampling procedure will be established as part of the DR/QR effort to ensure that the capscrews are of the specified length, 2) the capscrews will be installed as recommended by Stone & Webster, and 3) torque is checked following the first period of engine operation after gasket replacement.
REFERENCE Battelle Pacific Northwest March 1985 Technical Evaluation Repoct, " Review of Emergency Diesel Generator Air Start Valve Capscrews", PNL-5200-21.
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Technical Evaluation R,eport REVIEW 0F EMERGENCY DIESEL GENERATOR AIR START VALVE CAF5 CREWS w..-
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March 1985 i.
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Prepared for the U.S. Nuclear Regulatory Commission Division of licensing Office of Nuclear Reactor Regulation under Contract DE-AC06-76RLO 1830 NRC FIN B2952 Project
Title:
Assessment of Diesel Engine Reliability / Operability NRC Lead Engineer:
C. H. Berlinger Pacific Northwest Laboratory Richland, Washington 99352 8
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FOREWORD This report is supplied as part of the Technical Assistance Project, Assessment of Diesel Engine Reliability / Operability, being condtseted-for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor hulation.
Division of Licensing, by the Pacific Northwest Laboratory. The U.S. Nuclear Regulatory Commission funded this work under authorization B&R 20-19-40-42-1 FIN No. 82952.
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PACIFIC NORTHWEST LABORATORY PROJECT APPROVALS L
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W. W. Laity, Project Manager Pacific Northwest Laboratory w.--
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Date l'M ' 99 W. D. Richmond, Chairman Senior Review Panel Pacific Northwest Laboratory 6-a G
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ACKNOWLEDGMENTS This report was compiled by PNL project team members F. R. Zaloudek, R. E. Dodge, and M. Clement based on technical contributions proiided.by PNL consultants S. H. Bush, A. J. Henriksen, and B. J. Kirkwood.
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ABSTRACT This report documents Pacific Northwest Laboratory's (PNL), review of the Owners' Group resolution of a known problem with air start valv[ caps ~ crews used on Transamerica Delaval, Inc. (TDI), emergency diesel generator [' installed in nuclear power plants. The Owners' Group. efforts are described in the Stone &
Webster Engineering Corporation report, Emergency Diesel Generator Air Start Valve Capscre. Dimension and Stress Analysis (March 1984), and its supplement (April 1584).
i The Stone & Webster report and supporting calculations were reviewed by PNL and its consultants.
Based on this review, PNL concurs with the Owners' Group that the air start valve capscrew design is adequate for the intended
- service when installed and torqued as specified by the Owners' Group and whe'n the torque is rechecked after the first period of operation following
-installation of a new gasket.
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CONTENTS FOREWORD....................................................,[,,,,,,,,,,
gj PACIFICNORTHWESTLABORATORYPROJECTAPPROVALS.................{g........
iii ACKNOWLEDGMENTS..........................................................
iv ABSTRACT.................................................................
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1.0 INTRODUCTION
1 1.1 FAILURE HISTORY................................................
1 1.2 COMPONENT DESIGN...............................................
1
- - 2 <0- OWN ERS ' GROUP RESOLUTION OF PROBLEM................................'.
3 1
a= - --
2.1 ~ S C O P E OF EF FO R T................................................
3 J
2.2
SUMMARY
OF RESULTS.............................................
3 3.0 PNL'S EVALUATION....................................................
4
4.0 CONCLUSION
S AND RECOMMENDATIONS.....................................
6 REFERENCES...............................................................
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REVIEW OF EMCRGENCY DIESEL GENERATOR AIR START VALVE CAPSCREWS t
1.0 INTRODUCTION
i' The Pacific Northwest Laboratory (PNL) is supporting the U.S. Nuclear Regulatory Connission (NRC) staff in addressing questions of the reliability, operability, and quality assurance of Transanerica Delaval, Inc. (TDI) diesel engines used to provide standby power in some nuclear power plants.
These questions were raised because of a major failure in one TDI diesel at the Shoreham Nuclear Power Station in August 1983 and other problems encountered with TDI diesels. One of the principal tasks in PNL's effort is to evaluate the resolution by the TDI Diesel Generator Owners' Group of known problems w$Ith potential generic applicability.
This report documents PNL's evaluation of the Owners' Group resolution of problems identified with the air start valve capscrews installed in als TDI
~
l nuclear service engines used by the Owners' Group.
The details of the resolu-i tion of this problem were described in the report, Emergency Diesel Generator Air Start Valve Caoscrew Dimension and Stress Analysis (Ma*ch 1984), by Stone
& Webster Engineering Corporation, a consultant to the Owners' Group.
7-1.1 FAILURE HISTORY To date, no failure of air start valve capscrews has occurred.
- However, g,
at Shoreham and Grand Gulf the air start valve capscrews have loosened during operation because of a " bottoming out" in the cylinder head tapped hole durihg torquing.
This problem was corrected by replacing the original 3-inch-long capscrews with new, slightly shorter, 2-3/4-inch capscrews.
1.2 COMPONENT DESCRIPTION The shortened air start valve capscrews are fabricated from SAE grade 5 (min.) material, 2.75 inches long, with 3/4-inch 10N-3A type thn'eads.
Figure 1 l
illustrates the dimensions and installation of the capscrews.
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FIGURE 1.
Air Start Yalve Assembly
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Source:
Stone & Webster Engineering Corporation (March 1984) 7, l
2
2.0 OWNERS' GROUP RESOLUTION OF PROBLEM
~
This problem area was addressed by Stone & Webster Engineer,ing Corpora-
~
tion, a consultant to the Owners' Group. The objective of their.revi&w was to evaluate the functional attributes of the shorter TDI air start Yelve capsCrews.
2.1 SCOPE OF EFFORT Stone & Webster completed the following specific tasks as part of their review:
performed a dimensional check on the air start valve capscrews to e
' ' " ~
"~ determine'if adequate clearance exists within the cylinder head tapped hole
~
,e determined if the specified torque value ensures adequate capscrew preload e determined the total resultant bolt stress evaluated TDI's recommended retorquing requirements.
e The details of this analysis are provided in Stone & Webster calculation number 11600.60-245.1-M3.
7-2.2
SUMMARY
OF RESULTS The Stone & Webster report concluded that the 2-3/4-inch-long air start
}I~.
val"ve capscrew design is adequate for the given service conditions.
In addition, Stone & Webster's report concluded the following:
A dimensional check indicates that a 0.2-inch minimum clearance e
exists within the cylinder head tapped hole.
As a result, the air start valve capscrew will not " bottom out" upon torquing.
4 Fatigue failure in capscrews is avoided if two criteria are met:
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- 1) the total applied mean stress (S ) is below the yield point (S )
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for the component material and 2) the endurance strength exieeds the
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cyclic stress by an acceptable margin.
The total applied mean stress 3
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(S ) taken at the minimum cross-sectional area A(min.) is 37.5 ksi.
t The yield strength for the capscrew material is 92 ksi minimum. As a result, the first criterion for a fatigue-resistant design, namely, St
- S, is satisfied. Theendurancestressis9.0ksiand{the y
cyclic stress is +J.6 ksi. Accordingly, the second criteripn for a fatigue-resistant design is also satisfied. The recommended preload serves to reduce the range of stress cycling and subsequent fatigue effects on the capscrews. As a result, the specified torque that piivides the preload is acceptable.
During engine startup, a stress is imposed on the capscrews due to e
starting air pressure within the air start valve assembly. This stress is_. insignificant compared to the greater alternating stress -
indu.ced by cylinder firing pressures, During engine operation, the valve assembly copper gasket is sub-e jected to elevated temperatures.
As a result of the temperature rise and oreload, creep occurs within the gasket, which will decrease the total capscrew preload. To compensate, the existing diesel engine maintenance procedures require retorquing at specified intervals until no change is detected. At this time the gasket is fully com-pressed at its operating temperature by the required prelcad.
- Hence, 7--
capscrew preload is maintained during the full range of engine operation.
+
3.0 PNL'S EVALUATION The Stone & Webster report, Emergency Diesel Generator Air Start Valve Caoscrew Dimension and Stress Analysis, was evaluated by:
e M. Clement, PNL proj?ct team o
S. H. Bush, consultant, Review and Synthesis Associates A. J. Henriksen, consultant B. J. Kirkwood, censultant, Covenant Engineering.
i 4
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As a result of the initial review, the PNL reviewers requested additional infomation and supporting co'.culations (Laity April 23,1984).
Handwritten calculations (Stone & Webster calculation 245.1-M3) and additional infomation were received in reply (Ray June 20, 1984).
The Stone & Websterirepor.t. the supplemental handwritten calculations, and written responses to kNL's questions fomed the basis for the review of the Owners' Group resolution of the air start valve capscrew problem.
PNL reviewed the details of the Stone & Webster analysis, including:
e the review of dimensions of the shorter capscrew and the threaded hole showing that it would not be possible for the capscrew to
" bottom out" T the calcul'ation of the factor of safety for yield of the capscrew
~~
~~
under the maximum imposed non-operating load
,o the comparison of the maximum operating capscrew stress to the yield strength of the capscrew material the fatigue analysis of the capscrew using ~a Goodman diagram.
e PHL detemined that the analytical methods used by Stone & Webster were consistent with standard engineering practice and were appropriately applied.
All assumptions used in the analysis were found to be conservative.
The Stone & Webster analysis indicated that 1) the new 2-3/4-inch cap-screws would not bottom out 2) their maximum stress is well below the yield stres:;, and 3) they are not subject to fatigue failure if installed with the 7,
specified preload. PNL concurs with these conclusions, provided that 1) ther,e is sufficient assurance that the capscrews installed have the proper length and
- 2) the preload on the capscrews is properly established and maintained.
The concern with the preload is that the copper gasket used in the installation of the air start valve would creep under the sustained loading from the capscrews,'
resulting in a diminution of the preload.
Both these issues were addressed in the Stone & Webster report, Supplement to the Emergency Diesel Generator Air Start Valve Capscrew Dimention and Stress Analysis ( April 1984).
In this report, it was recomended that the capscrew l
t
i length be measured, on a sample basis, as a part of the DR/0R effort for each plant. Also, an installation procedure was recommended to ensure that the proper preload was imposed on the capscrews.
The procedure calls for th.
initial installation of these capscrews with 150 ft-lb torque followed by retorquing every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> until no further change is noted in the[ torque.
PNL concurs with the procedure; however, PNL recommends that the torque on these capscrews be checked following the first period of engine operation after a new gasket is installed, to ensure that no additional gasket creep occurs as a result of the additional thermal and mechanical stresses.
4.0 CONCLUSION
S AND RECOl1MENDATIONS, n.-
On the basis of the review of the referenced documents and calculations' provided by the TDI Owners' Group, PNL concurs that the described design for the air start valve capscrew is acceptable for the intended service.
This conclusion assumes that 1) a sampling procedure will be established as part of the DR/0R effort to ensure that the capscrews are of the specified length,
- 2) the capscrews will be installed as recommended by Stone & Webster, and
f-REFERENCES
=.
L a i ty, W. W. April 23, 1984.
Letter to Mr. Carl Berlinger, " Preliminary PNL Review of Report, Emergency Diesel Generator Air Start Valve Capscrew Dimension and Stress Analysis, Stone & Webster Engineering Corporation, Boston, Massachusetts, Marcn 1984."
Ray, C.
L., Jr. June 20, 1984.
Letter OGTP-85 to C. Berlinger transmitting answers to PNL's previous questions.-
2 6
Stone & Webster Engineering Corporation. March 1984 Emergency Diesel Generator Air Start Valve Capscrew Dimension and Stress Analysis.
- Boston, Massachusetts.
L Stone & Webster Engineering Corporation. April 1984
" Air Stadt Valve Capscrew Dimension and Stress Analysis." Calculation 11600.dD'-245.1-M3, Boston, Massachusetts.
Stone & Webster Engineering Corporation. April 1984.
Supplement to the Emergency Diesel Generator Air Start Yalve Capscrew otmension and stress Analysis.
Boston, Massachusetts.
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PNL-5200-21 DISTRIBUTION No. of No. of Copies copies OFFSITE P. Lang, NE-14 hs U.S. Department of Energy 16 Division of Licensing Office of Nuclear Energy Office of Nuclear Reactor Washington, DC.20555 Regulation U.S. Nuclear Regulatory ONSITE Commission Washington, DC 20555 DOE Richland Operations Office ATTN:
C. Berlinger (10)
M. Carrington (2)
H. Ransom /M. Plahuta D. Corley F. Miraglia Pacific Northwest Laboratory-H. Thompson M. Williamsk 2 Consultants 12 NRC Plant Project Managers A. Henriksen Division of Licensing B. Kirkwood U.S. Nuclear Regulatory Commission 5 Senior Review Panel
'5 Washington, DC 20E55 ATTN:
B. Buckley F. Albaugh S. Burwell S. Bush D. Hood C. Hill D. Houston W. Richmond K. Jabbour L. Williams T. Kenyon E. McKenna 27 Project Team M. Miller S. Miner J. Alzheimer C. Stable A. Currie
=--
J. Stefano D. Dingee E. Weinkam R. Dodge W. Gintner 2
U.S. Nuclear Regulatory W. Laity (20)
Commission J. Nesbitt Public Document Room F. Zaloudek Division of Technical Information and Document Technical Information (5)
Control Publishing Coordination (2)
Washington, DC 20555 n'
Distr-1 l
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'63 SEPy A10 33 h
L y e,j%;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 44 In the Matter of' GEORGIA POWER COMPANY,
)
Docket Nos. 50-424 et al.
)
50-425
)
(0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " STAFF"S RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF JOINT INTERVENORS' CONTENTION 14 (TDI DIESEL GENERATORS)" and Supporting Documents in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Huclear Regulatory Comission's internal mial system,~ this 23rd day of September, 1985.
Morton B. Margulies, Esq., Chairman
- Mr. Gustave A. Linenberger, Jr.*
Admitistrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board 1
Panel Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris
- Bradley Jones, Esq.
Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Panel Suite 3100 U.S. Nuclear Regulatory Comission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303 Bruce W. Churchill, Esq.
Douglas C. Teper David R. Lewis, Esq.
1253 Lenox Circle l
Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1800 M Street, N.W.
Washington, D.C.
20036
~
L
. Atomic Safety and Licensing Laurie Fowler, Esq.
Board Panel
- 218 Flora Ave. NE U.S. Nuclear Regulatory Commission
. Atlanta, GA 30307 Washington, D.C.
20555 Docketing and Service Section*
Atomic Safety and Licen:ing Office of the Secretary-Appeal Board Panel
- U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James E. Joiner, Esq.
Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.
. & Ashmore P.O. Box 2625 127 Peachtree Street, N.E.
Birmingham, AL 35202 Candler Building, Suite 1400 Atlanta, GA 30043 Tim Johnson Executive Director Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.
Atlanta, GA 30303 i
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Lee Scott Dewey 4
Counsel for NRC Staff L/
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