ML20093M138

Status Rept on Number of Developments Re Diesel Generator Hearings.Certificate of Svc Encl.Related Correspondence

ML20093M138
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/17/1984
From:	Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
CON-#484-584 OL, NUDOCS 8410190405
Download: ML20093M138 (11)

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. LILCO, October 17, 1984 w

DOCKETED L U3tiRC UNITED STATES OF AMERRICA b NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board,r r er 3;g -

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In the Matter of ) 5

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LONG ISLAND LIGHTING COMPANY ) DOCKET NO. 50-322(OL) g (Shoreham Nuclear Power Station,

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STATUS REPORT a

1R The purpose of this report is to inform the Licensing [

Board of a number of developments relating to the diesel gener-ator hearings.

1. The SER Qualified Load and Confirmatory Testing Transamerica Delaval, Inc., Owners Group (TDI Owners Group) submitted its Program Plan for Staff review on March 2, 1984. On August 20, 1984, LILCO received the Staff's Safety Evaluation Report (SER) pertaining to this Program Plan. Based 4 on the Staff's review of the TDI Owners Group Program Plan and the status of Phase I of the DRQR, the Staff included provi- -

sions in the SER establishing an interim basis for licensing.

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i See SER at 6 4.6, pp. 13-19. Among the elements included in -

l the interim basis for licensing was a requirement for certain confirmatory testing. The SER stated the requirement and defined the " qualified load" in the following terms:

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1. For engines where emergency service load requirements involve a BMEP greater than 185 psig, the utility shall provide information demonstrating that crankshafts, pistons and other key engine components (as identified below) which are of the same design as those in the subject engines have operated success-fully for at least 10-7 loading cycles under loading conditions which meet or exceed the severity of the maximum emergency service load requirements for the subject engines.

For purposes of this SER, this load level (i.e., the load level above a load corre-sponding to 185 psig BMEP enveloped by suc-cessful operating experience) will be re-ferred to as the " qualified load" for the -

subject engine. Where appropriate operating experience does not already exist relative to this qualified load, a test of an engine with the same designs as of these key components for 10-7 cycles will be required to establish an adequate " qualified load" for the subject engines.1/

SER at 13-14.

In order to establish the qualified load for the con-firmatory testing, LILCO had to determine the maximum emergency '

service load requirements for the TDI engines at Shoreham.

This involved a two step process. First, LILCO performed an engineering evaluation of the diesel generator bus loading pro-gram to ensure that only essential, safety related loads were 1/ As the SER notes, this 10-7 cycle confirmatory testing of the qualified load is not required for those key components for which appropriate operating experience already exists. Thus, this testing is not required for the AE pistons at Shoreham be-cause the Staff has determined that the R5 engine experience with the AE piston, which far exceeds 10-7 cycles, is applica-ble to the Shoreham AE pistons. Accordingly, the 10-7 cycle confirmatory testing is relevant, in the context of the litiga-tion, only to the crankshaft.

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.placed on the buses during a' LOOP-LOCA' event. 'This effort was underway prior to the issuance of the Staff'SER and the re-sults, which' permitted a reduction in load to 3500 KW, were re-

' ported.by LILCO in SNRC-1065 and. presented to the Board during the July.5 Conference of Parties.

The.second portion'of the effort involved.the use of the actual diesel generator bus loads measured during testing .

as allowed by the Staff ~SER. Actual diesel bus loads were de-- -

termined through both the Integrated Electrical Tests (IET)

,- involving all three diesels as well as additional component-specific confirmatory testing. The compilation of IET data was completed and available on August 17, 1984. Additional component-specific testing was completed circa September 29.

After internal engineering review and analyses of these test results, the final qualified load for the Shoreham diesels was confirmed as 3300 KW on October 15, 1984. This week, LILCO is submitting to the Staff for its review and approval an ESAR re-vision stating the new qualified load and the information to support it.

While working to establish the new qualified load, LILCO also conferred with the Staff concerning aspects of the confirmatory testing required by the SER. LILCO and the Staff have now reached essential agreement on the major aspects of the confirmatory testing to be conducted. Pursuant to this agreement, LlLCO is testing Diesel Generator 103 at the new i

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_4 qualified-load of 3300 KW,'for a.totSl of 740' hours (the-equiv-

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alentiof 10-7 cycles) with' credit.to be given for all' hours ac-l cumulated at orlabove the n'ew qualified load since"the' instal-

lation'of1the' replacement crankshaft. Approximately-219 hours-0 1 have been accumulated at: or above the qualified load since the installationgof the replacement crankshaft.- ' Therefore, 521 ,

o hours'of operation at the qualified load remained for comple-tion of the-test. The:521' hours need not be the result of con-t tinuous operation because it is understood and contemplated by-LILCO and the Staff that shutdowns during the 521 hours0.00603 days <br />0.145 hours <br />8.614418e-4 weeks <br />1.982405e-4 months <br /> of op-erationimay occur for a variety of reasons such as routine maintenance and surveillance tests.

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LILCO commenced the test on Diesel Generator 103 on-October'8, 1984,2/ and it is currently anticipated that the

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completion of~the test and the post-test inspections will not

, occur before December 2, 1984.

In addition to the operation of the engine for a total

! of 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> at 3300 KW, LILCO has also undertaken to perform a variety of post-test inspections of various key engine compo-nents listed by the Staff in the SER. See SER pp. 8-9. In-cluded among the inspections currently contemplated are-liquid penetrant and eddy current inspections, as appropriate, of all t-2/ LILCO commenced the test prior to the final confirmation of the'new qualified load on-the basis of preliminary results then available.

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-S-fillet areasJand' oil'.holec of the crankshaft; except at l bearings.1h 2, 10.and .- 11. With respect torthe engine block,- x

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. pertinent inspections willcalso be conducted with respect to the cam gallery arealand the block top. Strain gauge measure-ements.wi111also:be'taken to' measure stresses in the cam galley area. .Asinoted,'LILCO does not expect to-complete the test and

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l the post-test inspections prior;to; December 2,-1984.

The reduction in the maximum emergency load tof3300~KW does not change the ultimate conclusions stated inLLILCO's-tes--

i timony concerning the adequacy of.the crankshaft, pistons and cylinder blocks to perform their intended functions. Rather,-

the load reduction increases the margin of safety and therefore gives further assurance that Shoreham's TDI diesels-can perform

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their intended function safely and reliably. Similarly, the confirmatory test program undertaken by LILCO also increases assurance that the diesels will perform reliably. LILCO does not, however, seek to-supplement or re-open the record at this

time to include this.information.

j' The present situation is analagous to that in l Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and'2), LBP-84-2, 19 NRCL36 (1984). In Byron, the parties lit-igat'ed allegations concerning the quality assurance programs of certain contractors involved in the construction of the plant.

While' hearings were underway, the applicant initiated a re--

inspection' program for the work of the allegedly deficient

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-s contractors. Although some information concerning the re-inspection program was presented to the Board, the record closed prior to completion of the effort. Ultimately, the:

Board found that the applicant had not met its burden of proof with respect.to quality assurance. In explaining its procedur-

-al approach, the Board stated:

Recognizing that the matter may not forever be closed, we explain further the signficance of our order. The Board considered the al-ternative of jnforming the parties now of the substance of our views on the quality assur-ance issues, retaining jurisdiction over them, and providing for further proceedings before us when the various inspections, in-vestigations and remedial actions become ripe for consideration.

19 NRC at 279. That Licensing Board decided instead to deny the license without further consideration of the re-inspections in progress.

The Appeal Board, however, rejected this approach, not-ing that the Licensing Board should have adopted the alternative of "in-

, forming the parties now of the substance of (its] views on the quality assurance issues, retaining jurisdiction over them, and providing for further pro,eedings before [it]

when the various inspections, investigations 7

and remedial actions become ripe for consid-eration.

Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2), ALAB-770, 19 NRC 1163, 1169 (1984).

In this case, LILCO has and will present evidence which meets its burden of proof with respect to the AE pistons, if

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not, settled,-the crankshaft and-the: block. :This evidence, in

'large measure,3/ does not address the new qualified load.

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Nonetheless, if after hearing:all the evidence, the' Board de-

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termines that-LILCO has not met'its burden of proof with re-

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spect to any contention,'it will face a situation similar to -

that faced by the Byron Board. .In light _of:the Appeal Board's guidance, it would then be. appropriate fo'r;this. Licensing Board

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to inform the parties of its views and ask for additional tes-timony on the lower loads and the confirmatory tests. Thus, LILCO does'not seek to re-open the record at this time. If, however, the Board desires additional information now, LILCO stands ready to provide supplemental testimony which would

, (1) describe the testing and analysis per-formed to develop the maximum actual i emergency loads and the results of that

testing and analysis; 1

(2) describe the confirmatory testing that LILCO has agreed to perform pursuant to-the requirements of the Staff's SER; and (3) summarize the effect of the 3300 KW actu-al load level on LILCO's previously stat-

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ed conclusions regarding the crankshaft, pistons and cylinder blocks.

2. Block Panel Size The original testimony filed by.LILCO on the block was sponsored by 12 witnesses. Such a large witness panel raises substantial practical concerns. Accordingly,.LILCO has-decided l 1

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l 3/ Load' levels of 3300 KW and other loads below 3500 KW~have been discussed in testimony'before the Board. See, e.g., Tr.

22,668-70,-22,809-10, 22,818-19, 23,000-03, 23,070-71.

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to reduce.the' size of the panel by excusing Clinton S. Matthews and Maurice H. Lowrey of TDI, John F. Wallace, a TDI consul-c tant, and Robert K. Taylor.of Failure Analysis Asso'iates (FaAA). When the hearing resumes on October 22, 1984, counsel

-for LILCO will take formal = steps to withdraw the testimony sponsored by Messrs. Matthews, Lowrey and Wallace. Mr. Taylor was not'the sole sponsor of any testimony and his removal from the panel requires no withdrawal of testimony. Thus, when the hearing resumes on October 22, the LILCO block panel will con-sist of Dr. Roger L. McCarthy

-Dr'. Charles A. Rau Dr. Clifford H. Wells Dr. Harry F. Wachob Dr. Duane Johnson Mr. Craig Seaman Mr. Edward J. Youngling Mr. Milford H. Schuster 4

LILCO believes this number of block witnesses is manageable and appropriate in light of the testimony filed.

3. Potential Piston Settlement-By letter dated October 11, 1984, from Tim Ellis, the Board was advised that LILCO had made a proposal to the County 1 for settlement of.the piston contention. On October 16, 1984, Counsel for the County advised LILCO's counsel that LILCO's proposal formed a basis for settlement discucsions to proceed.

I The parties will keep the Board advised of progress in this re- i gard.

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'4. Cylinder Head Settlement All parties have now signed the cylinder. head settle-ment agreement in the form originally submitted to the Board.

The s'igned agreement will be presented to the Board at an ap-

-_propriate time during the week of October 22 for the Board's-review and consideration.

Respecfully submitted, LONG IS LIGHTING' COMPANY

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7 Hunton & Williams P. O. Box 19230 Washington, D.C. 20036 .

Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 ,

DATED: October 17, 1984 i

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• 4 LILCO, October 17, 1984 '

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4 CERTIFICATE OF SERVICE  ?

,s "i In the Matter of g LONG ISLAND LIGHTING COMPANY 7 (Shoreham Nuclear Power Station, Unit 1) -

Docket No. 50-322 (OL) _

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I hereby certify that copics of STATUS REPORT were served a this date upon the following by first-class mail, postage pre-paid, by telecopier, as indicated by an asterisk, or by Federal Express, as indicated by two asterisks.

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5 Judge Lawrence Brenner, Esq.* Martin Bradley Ashare, Esq. 5_

Chairman Attn: Patricia A. Dempsey, Esq. Z Atomic Safety and Licensing County Attorney Board, United States Suffolk County Department -

Nuclear Regulatory Commission of Law _=

Washington, DC 20555 Veterans Memorial Highway -

Hauppauge, New York 11787 / -

Dr. Peter A. Morris

• f, I Administrative Judge Edwin J. Reis, Esq.* } , -

Atomic Safety and Licensing Bernard M. Bordenick, Esq.

Board, United States Office of ,the Executive Legal l

Nuclear Regulatory Commission Washington, DC 20555 Director U.S. Nuclear Regulatory

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i Commission r Dr. George A. Ferguson** Washington, D.C. 20555 _

Administrative Judge Atomic Safety and Licensing Herbert H. Brown,j Esq.*

• Board Panel Kirkpatrick, Lockhart, Hill, -

School of Engineering Christopher & Phillips Howard University 1900 M Street, N.W. '

3 2300 6th Street, N.W. 8th Floor =

Washington, D.C. 20059 Washington, D.C. 20036 Secretary of the Commission Mr. Marc W. Goldsmith U.S. Nuclear Regulatory Energy Research Group -

Commission 4001 Cotten Pond Road }

Washington, D.C. 20555 Waltham, Masschusetto 02154

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Atomic Safety and Licensing MHB Technical Associates 3 b

Appeal Board Panel 1723 Hamilton Avenue

U.S; Nuclear Regulatory Suite.K Cormission San Jose, California 95125 -

Washington, D.C. 20555 Mr. Jay Dunkleberger ,

Atomic Safety and Licensing New York State Energy Office ,

Board Panel - Agency Building 2

• U.S. Nuclear Regulatory .Ehpire State Plaza Y

Commission Albany, New York 12223 -

Washington, D.C. 20555 ,

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' Stephen B. Latham, Esq. Fabian G.' Palomino, Esq.**

iTwomey, Latham & Shea Special Counsel to the

.33 West Second Street Governor P. O. Box 398 .

Executive Chamber, Room 229 Riverhead, New York 11901 State Capitol-Albany, New York 12224 James B.:Dougherty, Esq.

3045 Porter Street Jonathan D. Feinberg, Esq.

Washington, D.C. 20008 New York State Department of Public Service Three Empixe State Plaza y., Albany, Meu York 12223

,, Robert E. Smith, Esq.

, . Guggenheimer & Unt : 'yer y

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80 Pine Street s New York, New York 10005  ;

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} Hunton & Williams I- 707 East Main Street '

I [ Richmond, Virginia 23219 .

'3 s 9 DATED: October 17, 1984 1

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