ML20133B859
| ML20133B859 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/31/1985 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20133B788 | List: |
| References | |
| OL, NUDOCS 8508060276 | |
| Download: ML20133B859 (14) | |
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v July 31,D$$5ED 1
USNRC 15 Adi-5 N0:46 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION LFFicE DF SECRtTAli' 00CnETg}ERVICf.
BEFORE THE ATOMIC SAFETY AND LICENSING B~0ARD In the Matter of
)
)
)
Docket Nos. 50-424
)
50-425
)
(Vogtle Electric Generating
)
Plant, Units 1 and 2)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION 14 Pursuant to 10 C.F.R.
$ 2.749(a), Applicants, in support of their Motion for Summary Disposition of Conten' tion 14, state that there is no genuine issue to be heard with respect to the following material facts:
1.
Contention 14 states there is no reasonable assurance that the four Transamerica Delaval, Inc. ("TDI") diesel genera-tors in place at the Vogtle Electric Generating Plant ("VEGP")
l will provide a reliable and independent source of emergency on-site power, as required by 10 C.F.R. Part 50, Appendix A, General Design Criteria ("GDC") 17, in that their design, manu-l l
facture and associated quality assurance / quality control l
0500060276 850731 PDR ADOCK 05000424 9-PDR
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i procedures have resulted in' substandard engines subject to com-mon mode failures.
ASLB Memorandum and Order, September 5,-
1984.
t 2.
Two TDI'Model DSRV-16-4 diesel generators are pro-
)
vided for redundancy at each Unit at VEGP.
Affidavit of Larry L. Eppler ("Eppler Affidavit"), 11 3, 5.
The diesels are physically and electrically isolated from each other.
Ig,.
1 4.
The diesels are rated at 7,000 kw for continuous opera-tion.
Id., 1 3.
In the event that loss of offsite power l
causes a forced plant shutdown, the maximum calculated load au-tomatically sequenced onto the engines (as indicated in the i.
VEGP Final Safety' Analysis Report ("FSAR")), is 5,517 kw, only 5
]
79% of the engines' continuous operation rating.
Id.
The VEGP engines, therefore, have more than adequate capacity to handle the most severe design basis sequenced loading.
Id.
3.
TDI diesel generators were widely used in non-nuclear j
applications for years prior to VEGP's purchase of its engines I
in 1976.
See Affidavit of John C. Kammeyer ("Kammeyer Affida-vit"), 1 5.
TDI diesel generators had already been ordered for j
twelve other-nuclear power facilities by the time the VEGP en-gines were ordered.
Id.
l-4.
The TDI Diesel Generator Owners Group Program, as im-plemented via VEGP's Emergency Diesel Generator Resolution Pro-t l
gram ("EDG Resolution Program"), provides assurance that the 4 !,
I i
t i
TDI diesel generators will reliably perform their safety-related functions by establishing both the reliability and acceptability of their critical engine components.
Id.
1 91; see generally Affidavit of Steve A. Phillips ("Phillips Affidavit").
The Program established by the Owners Group pro-vided an in-depth assessment of the VEGP diesel generators' ability to perform their safety-related functions through a se-ries of component design reviews and quality revalidations, en-gine tests, component inspections, and the establishment of maintenance and surveillance requirements.
Kammeyer Affidavit, 11 8, 9.
5.
The NRC Staff evaluated the Owners Group Program Plan and concluded that it incorporated the essential elements needed to resolve the outstanding concerns relating to the reliability of the TDI diesel generators for nuclear service, and to ensure that they comply with GDC 1 and GDC 17.
Id.,
1 9.
6.
Georgia Power Company ("GPC") was a member of the Owners Group and, through its on-site EDG Resolution Program, actively participated in the Owners Group Program.
Id.,
1 6.
See generally Phillips Affidavit.
7.
High-quality technical resources were used to imple-ment the Owners Group Program.
Kammeyer Affidavit, 8.
Spanning over a year's time, more than a hundred engineers and l
technicians were involved in the Phase I effort alone.
Id.,
1 14.
8.
The Owners Group initially compiled a comprehensive database on TDI diesel generator operating experience to pro-vide a foundation for the selection of components for review.
Id. 11 10, 76.
The database included information from both nuclear and non-nuclear industry experience, as well as utility site-specific experience with diesel generators.
Id.
9.
The Phase I effort of the Owners Group Program iden-tified each significant known problem with potentially generic applicability to TDI diesel generators.
Id.,
1 10.
Sixteen components were identified for which specific design and/or manufacturing concerns were raised and resolved through analy-ses, testing, and documentation reviews.
Id.,
11 10, 11.
10.
A detailed design review of each of these sixteen components was conducted by the Owners Group consultants.
Id.,
1 11.
Their findings and final recommendations are outlined in a series of thirty-six separate reports.
Id.,
1 14.
The Phase I reports also contain recommendations for maintenance, testing, and inspection of components.
Id.
The Phase I re-ports were submitted to the NRC Staff for review.
Id.
The Staff has issued Safety Evaluation Reports ("SERs") for three of the Phase I components, the wiring and termination, airstart valve capscrews, and rocker arm capscrews.
See SERs:
Wiring. _ _. _ _ _ _ _ _ _
l
'and Termination (June 25, 1985), Air Start Valve Capscrews (June 17, 1985), Rocker Arm Capscrews (June 17, 1985).
In all cases, the Staff concluded that the components are adequate for service, provided the Owners Group recommendations, and proper installation and maintenance procedures are followed.
Id.
l 11.
While TDI drawings and certain TDI information were used as input to the owners Group review of the diesel genera-tor components (in both Phase I and Phase II, as discussed below), all technical evaluations were performed independently of TDI.
Id.,
1 12.
Independent design verification of each component requiring a design review was achieved by a review of the service history, the establishment of a methodology for verification of the critical attributes of the component and their evaluation by the Owners Group, not by a review of TDI's analyses.
Id.
The Owners Group Program achieved independence from TDI's quality assurance program by the inspection and testing of the TDI diesel generator equipment installed at each site, including VEGP.
Id.,
1 13.
These inspections were per-formed by Owners Group and/or VEGP site personnel.
Id.
- Thus, critical aspects of components actually installed in the VEGP diesels were verified independent of TDI.
Id.
12.
Based on recommendations generated in Phase I of the Owners Group Program, the VEGP engine components with poten-tially generic problems either have been, or will be inspected, replaced, and/or modified by VEGP personnel during the complete.
disassembly of each of the VEGP engines conducted as part of VEGP's on-site EDG Resolution Program.
See Phillips Affidavit, 11 4-8, 23, Ex. 2.
During engine disassembly, components are visually inspected for signs of wear or damage.
See id.,
1 4,
7, 8, Ex. 2.
Proper installation and preloading are verified, as necessary.
Id.
Nondestructive examinations o~f certain en-gino components are performed.
Id.
In come cases, testing of component material and/or hardness is called for.
Id.
This effort will be completed prior to fuel load.
Id.
17, 8,
23.
13.
Ongoing maintenance and surveillance recommendations from the Owners Group for the Phase I components will be incor-porated into the engine maintenance and surveillance program at the plant.
See id.,
11 9-11.
VEGP is committed to imple-menting each of the Owners Group maintenance and surveillance recommendations.
Id.,
1 11.
VEGP will also perform the testing and inspection of Phase I components recommended by the owners Group after engine operation.
See id. 1 22.
14.
Based on the owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' turbochargers are acceptable for their intended nuclear service.
See Kammeyer Affidavit, 1 62.
15.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and.
maintenance and surveillance recommendations, the TDI diesel generators' base and bearing caps are acceptable for their intended nuclear service.
See id.,
1 23.
16.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' crankshafts are acceptable for their. intended nuclear service.
See id.,
11 68-69.
17.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' cylinder blocks and cylinder liners are acceptable for their intended nuclear service.
See id.,
11 53, 57, 18.
Basede.on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-i nance and surveillance recommendations, the TDI diesel genera-tors' cylinder head studs are acceptable for their intended nuclear service.
See id.,
1 33.
19.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' connecting rods are acceptable for their intended nuclear service.
See id.,
1 72.
I -
20.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' connecting rod bearing shells are acceptable for their intended nuclear service.
See id.,
1 28.
21.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' pistons are acceptable for their intended nuclear ser-vice.
See id., V 52.
22.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' airstart valve capscrews are acceptable for their intended nuclear service.
See id.,
1 36.
23.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' cylinder heads are acceptable for their intended nuclear service.
See id.,
V 46, 24.
Based on the Owners Group evaluations, as well as the implementation of applicable inspection, testing, and mainte-nance and surveillance recommendations, the TDI diesel genera-tors' fuel oil injection tubing is acceptable for its intended nuclear service.
See id.,
- 19. l
-~
25.
Based on the Owners Group and evaluations, as well as j
the implementation of applicable inspection, testing, and main-tenance and surveillance recommendations, the TDI diesel gener-ators' main and connecting pushrods.are acceptable for their intended nuclear service.
See id., 1 42.
l l
26.
Based on the owners Group and evaluations, as well as I
t the implementation of applicable inspection, testing, and main-l l
tenance and surveillance recommendations, the TDI diesel gener-l ators' rocker arm capscrews are acceptable for their intended nuclear service.
See id.,-1 16.
27.
Based on the Owners Group and evaluations, as well as the implenentation of applicable inspection, testing, and main-l tenance aad surveillance recommendations, the TDI diesel gener-ators' jacket water pumps are acceptable for their intended nuclear service.
See id., 1 65.
l 28.
Ere.ed on the owners Group and evaluations, as well as the implementation of applicable inspection, testing, and main-tenance and surveillance recommendations, the TDI diesel gener-ators' wiring and termination is acceptable for its intended nuclear service. See id., 1 31.
i 29.
Phase !! of the Owners Group Program examined the im-portant components of each owner's engines which were not re-
[
i viewed in the Phase I effort from the standpoint of both design j
i and quality attributes.
Id., 1 75.
These components did not I
f m
t have a history of problems associated with them.
Id.
171 com-1 ponents were reviewed for the VEGP engines in the Phari II pro-i gram.
Id., 1 85.
i 30.
The Phase II components were chosen on the basis of l
j past nuclear and non-nuclear engine experience, as well as site-specific experience, as entered into the comprehensive database discussed supra.
Id., 1 78.
The effect the compo-nont's failure would have on the performance of the diesel gen-1 erator was also evaluated and each component was classified ac-cording to its criticality.
Id., 1 77.
j 31.
Appropriate design review and quality revalidation requirements were established for each component, as reflected in the more detailed task descriptions (" Component Revalidation Checklists") which were prepared for each component.
Id.,
1 82.
Components whose fai' lure would result in immediate die-sel generator slatdown or prevent start-up under emergency con-i ditions normally required a full design review and quality revalidation.
See id.,
11 77, 78.
The task description for each VEOP component either has been, or will be implemented by a VECP task force at the site; detailed design reviews were conducted by the owners Group.
Id., 1 82; Phillips Affidavit, 11 4-8, 24, Ex. 2.
The VEGP DR/QR Report for Unit 1, prepared by the Owners Group, was transmitted to the NRC on January 18, 1985.
Phillipo Affidavit, 1 6.
This document incorporates the information contained in the 12-volume report prepared by VEGP
, D
to document its Unit 1 engine revalidation effort.
M.,
1 6; l
Kammeyer Affidavit, 1 82.
32.
Under VEGP's EDG Resolution Program, the diesels have been inspected and certain Phase II components subjected to I
nondestructive examinations, repair and/or modification, etc.
I (as discussed previously, with reference to the Phase I compo-t nents), while the engines were disassembled.
See Phillips Af-fidavit, 11 6-8, Ex. 2.
The Phase II quality revalidation ef-fort is nearly complete on the VEGP diesels.
M.,
11 7-8.
As f
noted in the VEGP DR/QR Report, selected engine components (as l
r recommended by the owners Group), will be reinspected following l
l various intervals of operation on each of the engines.
M.,
j 1 22.
With two possible exceptions, VEGP is implementing all l
applicable design modifications resulting from Phase !! of the Owners Group Program.
See Eppler Affidavit, 11 7-8, Ex. 2.
The two exceptions have been reviewed by Bechtel and determined to be appropriate for the conditions at VEGP.
See id.
All r
other design modifications will be in place prior to fuel load.
M.,
1 9.
33.
Where the Owners Group recommended ongoing mainte-
[
l nance and surveillance for a Phase II component to assure its l
l reliable performance, these maintenance and surveillance f
requirements will be incorporated into the ongoing VEGP pre-l ventative maintenance and surveillance program.
Phillips Affi-
[
davit, 11 9, 11.
VEGP will implement each of the Owners Group f
[,
l l
j l
i.
maintenance and surveillance requirements for the Phase II com-ponents.
See id., 1 11.
34.
The VEGP diesel generators will be subjected to a comprehensive testing program prior to plant licensing and operation.
Id., 1 18.
This program will provide additional assurance of the reliability of the TDI diesel generators' ability to perform their intended safety-related function.
Id., 11 18, 25.
35.
The preoperational engine test program for the diesel engines is based on IEEE-387-1977 and NRC Regulatory Guides 1.108 and 1.9, as committed to in the VEGP FSAR.
Id., 1 21.
The program also includes testing and inspection recommenda-tions developed by the owners Group.
Id., 1 22.
36.
The VEGP diesel generator control logic and auxiliary systems will be tested.
Id., 1 21.
Testing will demonstrate the proper functioning of the electrical and pneumatic controls for the diesel generator auxiliary systems, which include the starting air, jacket wate;, lube oil, and fuel oil systems.
See id.
Diesel generator tests will be conducted at VEGP to demonstrate the en'gines' ability to start five times on each air storage tank.
Id.
The engines' ability to synchronize with offsite power will be demonstrated.
Id.
37.
Integrated testing of the diesel generators will be conducted to demonstrate the engines' response to a Loss of -
r Offsite Power (" LOOP"), Loss of Coolant Accident ("LOCA"), and LOOP /LOCA ovent.
Id.
Each diesel generator will demonstrate its operational capacity at 100 porcent load for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Id.
Each diesel generator's capability to reject 100 percent rated load as well as its response to the loss of the largest single load will also be tested.
Id.
A 35-consecutive ' start test will be conducted for each engine.
Id.
38.
The " lead" engines for the model DSRV-16-4 onginas at VEGP have already undergone full pre-operational testing.
Id.,
1 16.
The TDI DSRV-16-4 engines at Comanche Peak were tested in a program based on IEEE Standard 387-1977, Regulatory Guide 1.108, and the additional owners Group tests (including a torsiograph test of the crankshaft and engina vibration tests).
Id.
In excess of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of operation have boon logged on l
l these engines.
Id.
The TDI DSRV-16-4 engines at the Catawba plant have over 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> of operation.
Id., 1 17.
The suc-consful operation of thoso engines providos additional assur-ance of the capabilities of the TDI DSRV-16-4 engines at VEGP.
Id., 1 25, 39.
Testing recommended by tho owners Group to confirm the adoquacy of selected components will be performed at VEOP.
Soo id.,
1 22.
A torsiograph test to confirm the adequacy of the crankshaft to withstand operating torsional stresses will be performed.
Id.
An engino vibration survey will be ta'<en.
Id.
Additional testing, including cylindor imbalance testing, will be conducted.
Id. 11 19, 20, 22.
l 1..
.