Palmetto Alliance & Carolina Environ Study Group Responses to Util Interrogatories & Requests to Produce Documents on ASLB Contention Re Certain Diesel Generator Problems. Certificate of Svc Encl.Related CorrespondenceML20087P114 |
Person / Time |
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Site: |
Catawba |
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Issue date: |
04/01/1984 |
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From: |
Guild R GUILD, R., PALMETTO ALLIANCE |
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To: |
DUKE POWER CO. |
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References |
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NUDOCS 8404060065 |
Download: ML20087P114 (10) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20094H7321984-08-10010 August 1984 Supplemental Response to Joint Interrogatories & Requests to Produce Documents on Diesel Generator Contentions & to Carolina Environ Study Group Interrogatories.Prof Qualifications Encl.Related Correspondence ML20094H7651984-08-10010 August 1984 Interrogatories Re Identification,Qualifications & Role of Expert on Diesel Generator Contention.Certificate of Svc Encl.Related Correspondence ML20094A6331984-08-0101 August 1984 Response to Palmetto Alliance & Carolina Environ Study Group Seven Interrogatories for Which ASLB Granted Motion to Compel.Certificate of Svc Encl.Related Correspondence ML20090E5801984-07-18018 July 1984 Interrogatories & Requests for Production Directed to R Anderson on Newly Admitted Contention Re Diesel Generator Engine Problems.Certificate of Svc Encl.Related Correspondence ML20092K7121984-06-25025 June 1984 Supplemental Response to Joint Interrogatories & Requests to Produce Documents on Diesel Generators Contentions & Interrogatories Re Admitted Emergency Diesel Contentions. Related Correspondence ML20084D2201984-04-27027 April 1984 Supplemental Answers to Carolina Environ Study Group & Palmetto Alliance First Round of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20087P4201984-04-0606 April 1984 Response to Palmetto Alliance & Carolina Environ Study Group Interrogatories & Requests to Produce Documents on Diesel Generator Contentions.Related Correspondence ML20087P1141984-04-0101 April 1984 Palmetto Alliance & Carolina Environ Study Group Responses to Util Interrogatories & Requests to Produce Documents on ASLB Contention Re Certain Diesel Generator Problems. Certificate of Svc Encl.Related Correspondence ML20087N6661984-03-29029 March 1984 Supplemental Answers to Carolina Environ Study Group & Palmetto Alliance 840329 First Set of Interrogatories Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20087M4741984-03-25025 March 1984 Responses to Util Interrogatories & Request to Produce Documents on Diesel Generator Contention.Certificate of Svc Encl.Related Correspondence ML20087J4841984-03-22022 March 1984 Interrogatories & Requests to Produce Documents Re Diesel Generator Contentions to Applicant & NRC Staff.Certificate of Svc Encl.Related Correspondence ML20087J4901984-03-19019 March 1984 Supplemental Interrogatories to Util Re Emergency Diesel Contentions Admitted by Aslb.Certificate of Svc Encl.Related Correspondence ML20087G4121984-03-19019 March 1984 Interrogatories & Requests to Produce Documents to Carolina Environ Study Group & Palmetto Alliance on ASLB Contention Re Diesel Generator Reliability.Certificate of Svc Encl. Related Correspondence ML20087C4751984-03-11011 March 1984 Interrogatories & Requests to Produce Documents on Diesel Generator Contention to Carolina Environ Study Group & Palmetto Alliance.Certificate of Svc Encl.Related Correspondence ML20080G0121984-02-0606 February 1984 Responses to Second Round of Interrogatories Re Emergency Planning Contentions 1,3,6,7,8,9,11,15 & 18.Certificate of Svc Encl.Related Correspondence ML20079P7201984-01-26026 January 1984 First Round of Interrogatories Re Emergency Planning Contentions 1,3,6,7,8,9,11,14,15 & 18.Affirmation of Svc Encl ML20079J3631984-01-20020 January 1984 Second Round of Interrogatories Re Palmetto Alliance & Carolina Environ Study Group Emergency Planning Contentions 1,3,6-9,11,14,15 & 18.Certificate of Svc Encl.Related Correspondence ML20079L4551984-01-17017 January 1984 Response to First Round of Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14,15 & 18.Certificate of Svc Encl.Related Correspondence ML20083E5061983-12-22022 December 1983 First Round Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14-15 & 18. Certificate of Svc Encl ML20078A3981983-09-19019 September 1983 Supplemental Responses to Interrogatories & Requests to Produce Re Contention 6.Certificate of Svc Encl ML20077P2911983-09-0808 September 1983 Supplemental Responses to Interrogatories & Requests to Produce Re Contention 6.Certificate of Svc Encl.Related Correspondence ML20072F1731983-06-20020 June 1983 Response to Interrogatories & Requests to Produce Re Carolina Environ Study Group Contention 13.Affirmation of Svc Encl.Related Correspondence ML20072A5951983-06-0808 June 1983 Supplemental Response to Interrogatory 17 on Contention 7 ML20072A5921983-06-0606 June 1983 Responses to Util 830523 Followup Interrogatories on Des Contentions 11,17 & 19 ML20071N1701983-05-27027 May 1983 Further Supplementary Responses to Util Interrogatories Re Contentions 6,7,8,16 & 44 & NRC Interrogatories Re Contention 7 & Responses to Util & NRC Followup Interrogatories.Certificate of Svc Encl ML20071H0641983-05-18018 May 1983 Followup Interrogatories Re Des Contentions 11,17 & 19. Certificate of Svc Encl.Related Correspondence ML20073T1251983-05-0404 May 1983 Followup Interrogatories to Palmetto Alliance Contentions 6, 7,8,16 & 27.Answer Must Be Filed by 830520.Certificate of Svc Encl.Related Correspondence ML20023B7531983-05-0202 May 1983 Responses to 830418 Interrogatories & Requests to Produce Re Des Contentions 11,17 & 19.Related Correspondence ML20069L1451983-04-25025 April 1983 Interrogatories & Requests to Produce Re Contentions 1,2,3 & 4.Certificate of Svc Encl ML20073P1121983-04-20020 April 1983 Responses to 830401 Discovery & Document Production Requests Re Carolina Environ Study Group Contention 18 & Des Contention 17.Certificate of Svc Encl ML20073P6061983-04-19019 April 1983 Supplementary Responses to Interrogatories Re Contention 6, 7,8,16,27 & 44.Certificate of Svc Encl.Related Correspondence ML20073K4261983-04-18018 April 1983 Interrogatories & Requests to Produce Re Palmetto Alliance & Carolina Environ Study Group Joint Des Contentions 11,17 & 19.Certificate of Svc Encl.Related Correspondence ML20073G8301983-04-12012 April 1983 Addl Info to Initial & Followup Interrogatories.Related Correspondence ML20072R7361983-04-0101 April 1983 Discovery & Document Production Requests on Contention 18 Re Reactor Weld Cracks & Contention 17 Re Sandia Study Comparing Injury & Mortality Rates for Serious Accidents. Certificate of Svc Encl.Related Correspondence ML20072L5351983-03-28028 March 1983 Response to 830308 First Set of Interrogatories & Document Requests on Contention DES-17.Affirmation of Svc Encl. Related Correspondence ML20072N6081983-03-25025 March 1983 Responses to Palmetto Alliance 830316 Followup Interrogatories & Requests to Produce Documents Re Contentions 6,7,8,16,27 & 44.List of Major Plant Differences,Affidavits & Certificate of Svc Encl ML20072G3411983-03-17017 March 1983 Response to 821215 Second Set of Interrogatories & Document Production Requests.Affidavit of Svc Encl.Related Correspondence ML20069F5071983-03-16016 March 1983 Followup Interrogatories & Requests to Produce Re Palmetto Contentions 6,7,8,16,27 & 44.Certificate of Svc Encl.Related Correspondence ML20079P1331983-02-28028 February 1983 Supplemental Response to Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 6,7,8,27 & 44,in Response to ASLB 830209 Memorandum & Order.Certificate of Svc Encl.Related Correspondence ML20028C8801983-01-10010 January 1983 Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 8 & 27.Certificate of Svc Encl ML20064C4131982-12-31031 December 1982 Response to 820420 First Set of Interrogatories & Requests to Produce & 820927 Third Set of Interrogatories & Requests to Produce.Related Correspondence ML20028B9031982-12-0303 December 1982 Interrogatories & Requests to Produce Re Carolina Environ Study Group Contention 18/Palmetto Alliance Contention 44. Certificate of Svc Encl.Related Correspondence ML20028B4141982-11-22022 November 1982 Supplemental Responses to Third Set of Interrogatories & Requests to Produce.Certificate of Svc Encl.Related Correspondence ML20066C6301982-11-0606 November 1982 Supplementary Response to NRC & Util Interrogatories on Palmetto Alliance Contentions 8,16 & 27.Certificate of Svc Encl ML20069J3611982-10-19019 October 1982 Responses to Palmetto Alliance 820927 Third Set of Interrogatories & Requests to Produce.Related Correspondence ML20027B8811982-09-27027 September 1982 Third Set of Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 16 & 44.Certificate of Svc Encl ML20063M2051982-09-0303 September 1982 Second Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence ML20063J5121982-08-30030 August 1982 Responses to Applicant Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 8,16 & 27 & NRC Second Set of Interrogatories & Document Production Requests.Certificate of Svc Encl ML20062L5311982-08-16016 August 1982 Interrogatories & Requests to Produce Re Palmetto Alliance Contention 8.Certificate of Svc Encl.Related Correspondence ML20058J6881982-08-0909 August 1982 Interrogatories & Request to Produce Re Palmetto Alliance Contentions 16 & 27.Certificate of Svc Encl.Related Correspondence 1984-08-10
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20197J2871998-12-11011 December 1998 Initial Decision (Application for Senior Reactor Operator License).* Appeal of R Herring of NRC Denial of Application for SRO License Denied.With Certificate of Svc.Served on 981211 ML20151W5721998-09-11011 September 1998 NRC Staff Presentation in Support of Denial of Senior Reactor Operator License for Dl Herring.* Staff Decision to Fail Dl Herring on Category a of SRO Exam,Clearly Justified. Staff Denial of Herring SRO License Should Be Sustained ML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20237B6931998-08-13013 August 1998 Rl Herring (Denial of Operator License for Plant).* Rl Herring Submitted Written Presentation Arguments,Data, Info Matl & Other Supporting Evidence,Per Presiding Officer 980630 Order & 10CFR2.1233.W/one Oversize Drawing ML20237A3831998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Staff Respectfully Requests Motion for Extension of Time of 2 Wks to Respond to Herring Presentation Be Granted.W/Certificate of Svc ML20237B5571998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Granted by C Bechhoefer on 980818.W/Certificate of Svc.Served on 980818 ML20236T8511998-07-21021 July 1998 Specification of Claims.* Rl Herring Claims That Answer Given on Exam Was Correct When TSs Are Considered & When Design Basis Document Considered in Conjunction W/Duke Power Nuclear Sys Div.W/Certificate of Svc.Served on 980727 ML20236F5391998-06-30030 June 1998 Memorandum & Order (Hearing File & Spec of Claim).* Orders That Brief Spec of Claims Should Be Filed by Herring,Telling Why He Believes Staff Erred in Grading Exam.Staff Must Furnish Hearing File.W/Certificate of Svc.Served on 980630 ML20236F5631998-06-30030 June 1998 Notice of Hearing.* Presiding Officer Has Granted Request of Rl Herring for Hearing on NRC Denial of Application for Operator License for Plant.W/Certificate of Svc.Served on 980630 ML20149K8221997-07-29029 July 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Granted TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20065P4491994-04-21021 April 1994 Comment Opposing Proposed Rule 10CFR50.55 Recommendation to Incorporate Proposed Rule to Adopt ASME Code Subsections IWE & Iwl ML20044G7371993-05-25025 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20101R5931992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Opposes Rule ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20087F7471992-01-15015 January 1992 Comment Opposing Rev 1 of NUREG-1022, Event Reporting Sys ML20246J6571989-08-31031 August 1989 Order Imposing Civil Monetary Penalty on Licensee in Amount of $75,000 for Violations Noted in Insp on 881127-890204. Payment of Civil Penalty Requested within 30 Days of Order Date.Evaluations & Conclusions Encl ML20247J8921989-08-31031 August 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Violations Noted in Insp on 881127-890204,including Operation in Modes 1-4 W/One Independent Containment Air Return & Hydrogen Skimmer Sys Inoperable for 42 Days ML20205N1471988-10-20020 October 1988 Comment on Petition for Rulemaking PRM-50-50 Re Provision That Authorizes Nuclear Power Plant Operators to Deviate from Tech Specs During Emergency.Request by C Young Should Be Denied ML20234D2821987-09-15015 September 1987 Joint Intervenors Emergency Motion to Continue Hearing for 2 Wks & for Immediate Prehearing Conference.* Urges That Hearing Re Offsite Emergency Planning at Plant,Scheduled for 870928,be Continued Until 871013.Certificate of Svc Encl ML20198C5771986-05-14014 May 1986 Transcript of 860514 Discussion/Possible Vote on Full Power OL for Catawba 2 in Washington,Dc.Pp 1-86.Viewgraphs Encl ML20203N4561986-02-20020 February 1986 Unexecuted Amend 6 to Indemnity Agreement B-100,replacing Item 3 of Attachment to Agreement W/Listed Info ML20151P2231985-12-31031 December 1985 Order Extending Time Until 860110 for Commissioners to Review ALAB-825.Served on 851231 ML20136H7231985-11-21021 November 1985 Decision ALAB-825,affirming Remaining Part of ASLB OL Authorization,Permitting Applicant to Receive & Store Spent Fuel Generated at Duke Power Co Oconee & McGuire Nuclear Power Facilities.Served on 851121 ML20138B3611985-10-11011 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-813.Served on 851011 ML20137W4311985-10-0202 October 1985 Order Extending Time Until 851011 for Commission to Act to Review ALAB-813.Served on 851003 ML20134N5761985-09-0404 September 1985 Order Extending Time Until 851004 for Commission to Act to Review ALAB-813.Served on 850904 ML20126M2091985-07-30030 July 1985 Order Amending First Paragraph of Footnote 126 Re Need for Power & Financial Qualifications in ALAB-813 . Served on 850731 ML20126K7701985-07-26026 July 1985 Order Extending Time Until 850730 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850729 ML20129C2351985-07-26026 July 1985 Decision ALAB-813 Affirming Aslab Authorization of Issuance of Full Power Ol,Except Insofar as Receipt & Storage Onsite of Spent Fuel Generated at Other Facilities.Served on 850729 ML20129K1651985-07-19019 July 1985 Order Extending Time Until 850726 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850719 ML20129H9361985-07-10010 July 1985 Unexecuted Amend 5 to Indemnity Agreement B-100,changing Items 1 & 3 of Attachment ML20128K2171985-07-0808 July 1985 Order Extending Time Until 850719 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850709 ML20127P0991985-06-28028 June 1985 Transcript of 850628 Supplemental Oral Argument in Bethesda, Md.Pg 99-169 ML20133C5201985-06-26026 June 1985 Undated Testimony of PM Reep Re Welding Inspector Concerns. Rept of Verbal Harassment Encl ML20127K7171985-06-24024 June 1985 Order Extending Time Until 850709 for Commission to Act to Review Director'S Decision DD-85-9 ML20126K6391985-06-17017 June 1985 Order Advising That Counsel Be Familiar W/Content of Commission Request for Public Comment on Decision to Exercise Discretionary Price-Anderson Act Authority to Extend Govt Indemnity to Spent.... Served on 850618 ML20126B8101985-06-13013 June 1985 Order Scheduling Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md Re Public Notice of Hearing Concerning Use of Facility for Receipt & Storage of Spent Fuel from Oconee & Mcguire.Served on 850613 ML20126E4601985-06-13013 June 1985 Notice of Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md.Served on 850613 ML20125B4251985-06-0707 June 1985 Responds to Aslab 850603 Order Requesting Response to NRC 850529 Filing Re Whether Notice of Proposal to Use Catawba to Store Oconee & McGuire Spent Fuel Discretionary or Required.Certificate of Svc Encl ML20126A7631985-06-0404 June 1985 Director'S Decision DD-85-9 Granting & Denying in Part Palmetto Alliance Request for Mod,Suspension or Revocation of CPs for Facilities Due to Harassment & Intimidation of QC Inspectors ML20129A6381985-06-0303 June 1985 Order Allowing Applicant to File & Serve Response to NRC 850529 Assertion Re Storage of Spent Fuel Generated at Another Facility Constituting Use of Commercial Utilization Facility No Later than 850607.Served on 850604 ML20128P0001985-05-29029 May 1985 NRC Views on Whether Notice of Proposal to Use Facility to Store Oconee & McGuire Spent Fuel Required or Discretionary. Certificate of Svc Encl ML20128P1031985-05-29029 May 1985 Memorandum Responding to Palmetto Alliance/Carolina Environ Study Group & Staff 850517 Memoranda Asserting That Fr Notice Not Reasonably Calculated to Inform of Requests Re Spent Fuel.Certificate of Svc Encl ML20127K0231985-05-20020 May 1985 Order Extending Time Until 850529 for Aslab to Act to File & Svc Reply Memoranda.Served on 850521 ML20127G2281985-05-17017 May 1985 Memorandum Responding to 850425 Aslab Order Addressing Four Questions Re Receipt & Storage of Spent Fuel.Certificate of Svc Encl ML20127H0041985-05-17017 May 1985 Response to Aslab Questions on Adequacy of Notice of Proposed Use of Facility to Store Spent Fuel from Oconee & McGuire Facilities.Aslab Has No Jurisdiction Over Proposal. Certificate of Svc Encl 1998-09-08
[Table view] |
Text
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, TED CORgESPop0EN%
DCCxETED UNITED STATES OF AMEREb$r' NUCLEAR REGULATORY COMMISSION g Pa -3 N1:23 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD trrtcFOFSECT In the Matter of )
)
- $3@[Docket Nos. 50-413 Duke Power Company, et al. ) 50-414
)
(Catawba Nuclear Station, ) April 1, 1984 Units 1 and 2) )
)
PALMETTO ALLIANCE AND CAROLINA ENVIRONMENTAL STUDY GROUP RESPONSES TO APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE DOCUMENTS ON BOARD CONTENTION CONCERNING CERTAIN DIESEL GENERATOR PROBLEMS Palmetto Alliance and Carolina Environmental Study Group hereby provide their responses to Applicants' Interrogatories And Requests To Produce dated March 19, 1984, with respect to the Licensing Board sponsored contention reflecting,certain testing problems encountered by Applicants in the testing of Catawba j- Nuclear Station emergency diesel generator 1-A. The Board I
l contention was admitted by Memorandum and Order dated February 27,
- j. 1984. In that Memorandum and Order the Board admitted the l following contentions:
i l whether there is a reasonable assurance that the TDI emergency diesel generators at the Catawba station can
- perform their function and provide reliable service
- i. because of the problems. reported in the Applicants' l letter to the Board of February 17, 1984.
Memorandum-and Order (Admitting a Board contention concerning certain diesel generator problems) at p. 2, February 27, 1984.
I 8404060065 840401 PDR ADOCK 05000413 O' G PDR ._ )
Applicants' February 17, 1984, letter described the problems encountered in testing as follows:
More specifically, a minor amount of cylinder head leakage was noted during a run; when the engine was shut down it was discovered, during the week of February 5, that there was a slight crack in that cylinder head. Also during that week, the push rods for diesel generator 1-A were checked, and it was determined that some had flaws in the welds joining the ball to the pipe. We would note that all the push rods on
-diesel generator 1-A were subsequently replaced with push rods of an approved design. During the same week, one of the turbo chargers showed excessive ware (sic) on the rear bearing due to inadequate lubrication, a lube oil drain line leak, and a rupture of the lube oil prelude (sic) line for that turbo charger. Finally, during this run, a fuel oil injection pump nozzle was found to be cracked.
Id.,-attachment.
In the same Order the Licensing Board observed that:
1 (A)s the Applicants' letter points out, "these matters are similar in nature to matters found with other TDI diesels."
We expect, therefore, that litigation of this contention may involve us in proof of diesel operating histories from other nuclear plants with diesels of the same design.
-Id., at p. 3.. The Board further provides that discovery on this newly admitted contention should commence by a simultaneous l exchange of interrogatories on March 19, 1984, with responses to be exchanged by April 2, 1984. Intervenors Palmetto and CESG have
- served their Interrogatories and Requests for Production upon
! Applicants and the NRC Staff. Such discovery requests remain
-unanswered and outstanding at this time.
While this contention was admitted, sua sponte, by the Licensing Board, it is premised upon the same background and NRC Staff investigation as to the reliability of TDI emergency diesel
generators as was the Intervenors' original diesel generator
' contention which was the subject of the Memorandum and Order (Referring Certain Diesel Generator Issues to the Appeal Board) of February 23, 1984.
That Memorandum and order summarizes the Board Notification and related Staff documents which have served as the primary source of documentary information upon which Intervenors '
base their knowledge and position as to these matters. In addition to the generally circulated Staff documents, of which Intervenors believe Applicants and the NRC Staff have full knowledge since they, too, are recipients of such documents, Intervenors Palmetto and CESG have received a limited number of documents from Applicants with respect to this subject: Applicants 2/17/84 letter to the Board and parties describing the operational problems which are the subject of this contention; a 2/20/84 Mississippi Power and Light Company submittal to the NRC with respect to the problems and operating history od'its emergency diesel generators at its Grand Gulf Nuclear Station, upon which Applicants rely in large measure for qualifying the similar DSRV-16 diesels at Catwba; Applicants 2/22/84 submittal to the NRC Staff in response to the Staff's questions regarding the TDI diesel generators at Catawba with the attached " extended operation test of diesel generator 1-A" description; and, handouts distributed by Applicants at a 3/21/84 meeting in Bethesda, l Maryland with the NRC Staff with regard to the TDI diesel generator issue together with handwritten notes of Nina Bell, Esq., who attended the meeting as representative of Palmetto.
l
The above background sets forth the substance of Intervenors' knowledge and documentary sources on the basis of which we respond to Applicants' discovery.
R3 QUEST FOR DOCUMENTS Palmetto and CESG have identified herein certain documents in their possession, mostly documents known to be in the possession of Applicants themselves, which documents Palmetto and CESG will make available for inspection and copying by Applicants at a mutually agreeable time and place. In addition Palmetto and CESG have handwritten notes of their counsel and authorized representative prepared as hearing preparation materials or attorney work products which are privileged and not subject to
. production. Included in the latter category are notes of Nina Bell, Esq.
l INTERROGATORIES A. General Interrogatories
- 1. Robert Guild, Esq., Attorney for Palmetto Alliance and Jesse L. Riley, authorized representative of Carolina Environmental Study Group.
- 2. No witnesses have~been identified at this time although Intervenors anticipate the identification of various persons known to Applicants with knowledge of the results of Applicants' diesel' generator testing program and the problems which have occured in the 1-A diesel generator.
1
- 3. No . '
- -4. Intervenors understand that the problems reflected in this l
contention were the result of its own testing program of its diesel generator 1-A..
p L l
F
- 5. The documents identified above reflect the basis for our position on this contention.
- 6. Among the above documents are various Staff documents such as Board Notificiations and related circuit circulations known to Applicants.
i B. Specific Interrogatories
- 1. The lube oil prelube line is believed to provide lubrication for the turbo charger bearing while the diesel is in a standby mode.
- 2. See 1.
- 3. While in a standby mode.
- 4. According to Applicants' 3/21/84 meeting handout, " Improper Installation".
- 5. According to the same source Applicants had taken the following corrective action: " oil lines replaced properly, additional tubing clamps added, improved design to be installed June '84." Intervenors have insufficient information to know whether or not such fixes or modifications are adequate.
- 6. A, rupture of the lube oil prelube line would appear to present the potential for a lubrication deficiency in the turbo
- charger during a standby mode.
- 7. Possible interference with startup and limitation on diesel L generator power output. Such limited output might prevant t
! effective functioning during a station blackout where eighty percent capacity is required according to Applicants'
-submittals.
- 8. Insufficient information to answer at this time.
- 9. Not necessarily. The problem could induce failure at any time, including just af ter completion of the specified number of hours of operation. A'more predictive test might be multiple quick starts from~a standby mode; however, more ;
relevant quantitative data is required in order to specify an adequate demonstration.
- 10. As the name appears to suggest it drains lube oil from the turbo charger.
- 11. See 10.-
L . ,
1:2. Apparently in both the standby and operational modes.
- 13. According to Applicants' 3/21/84 meeting handouts, " drain line hose fatigue."
- 14. Also according to this same source Applicants took the following corrective action: " drain line hose replaced and improved design could be installed May ' 8 4. " .aditional data is required in order to express a view as to the adequacy of such fix or modification.
- 15. Leakage from the turbo charger lube oil drain line would appear to bleed off needed lubrication oil.
- 16. As described above loss of lubrication to the turbo charger bearing could result in a reduction of the diesel generator capacity by 25% power level. Such levels appear to be inadequate in the event of a station blackout emergency. -
- 17. Insufficient information to answer at this time.
- 18. IMt necessarily. The component might well fail later.
- 19. Don't understand question.
- 20. Poor design. Apparently variable thickness in the metal creates hot spots with differential expansion rates. Such a design may in part have caused the cylinder head cracking problem which has occurred at Catawba and in other TDI diesel generators, t
i
- 21. Competant redesign.
- 22. If such leakage rate is stable, a minimal effect.
i l .23. Depends on crack size stability. The crack in question at Catawba was once much smaller than it was upon discovery.
Cracks grow and propagate; a sufficiently large crack could lead to an overheacing failure in the diesel generator.
- 24. All other cracking experience appears to be relevant.
- 25. Not necessarily. As explained above such failure could occur at any time,-not necessarily during the testing period.
Insufficient empirical data exists to accurately predict the adequacy of a demonstration run.
- 26. Don't know.
- 27. Apparently functions in some fashion in injecting fuel oil.
- 28. Apparently.during engine operation.
L
- 29. According to Applicants' 3/21/84 meeting handout, " material defect."
- 30. According to the same source Applicants took the following corrective action: " pump replaced." Insufficient information exists to express a view as to the adequacy of this fix or
, modification.
- 31. Don't know.
~
- 32. Don't know, except that if the failure interrupts fucl oil supply to the diesel it will cease operation.
- 33. Don't know.
- 34. Not necessarily. As described.above such a failure might occur at any time, not necessarily during the testing period. -
- 35. While Intervenors lack sufficient informatica to respond to the question about continued operation with the linkage disconnected it appears that unless such a ruptured injection pump is replaced with a redundant system, an interruption of fuel flow to-the engine would prevent its functioning in an emergency. Without fuel the engine will not run.
- 36. Push rods connect the can shaft through the rocker arm to the valve stems.
- 37. They perform a linkage function in the operation of the valves.
- 38. Whenever the engine is running.
- 39. Apparently poor welds and fatigue stress.
4 0. . Insufficient information-is available to express an opinion as to the adequacy of a particular fix or modification.
- 41. The failure of a push rod could cause a loss of output for the affected cylinder.
- 42. Several failed push rods could reduce the diesel's output below the minimum required for emergency performance.
-43. Any.similar problems would be relevant to Catawba.
- 44. Don't know.
- 45. Yes, given the posited assumptions.
- 46. Yes, as well as a manufacturing deficiency.
L = . . - - . . ----------- - - - - - - - - - - - - -
. - ._. . - - - ~.
- 47. Don't know.
- 48. No. The fatigue limit may not have yet been reached.
- 49. Yes.
- 50. According to Applicants' 3/21/84 pleading handout, " Improper Lubrication."
- 51. (a) by drip process in the standby mode; (b) by regular lube oil pressure in operation.
- 52. Reduction of diesel generator output by 25%.
- 53. By Applicants' own performance requirement description diesels would not meet such requirements in a station i
blackout emergency or during a lowca when any other output limiting faults-occured such as loss of one cylinder or >
more.
- 54. The problem appears to be generic, including similar failures at San Onofre and Grand Gulf and in marine applications.
- 55. A series of quick start tests would appear to be a better measure.
- 56. The TDI proposal of March 23, 1984 is not yet known to Intervenors. Insufficient information exists to Intervenors to express an: opinion as to the adequacy of this fix or o modification.
- 57. No. Output would be reduced by 25% according~to Applicants..
, 58.- No. Even according to Applicants' 3/21/84 meeting handouts a i greater than 18.4~ percent reduction in output would prevent L effective operation during a station blackout emergency.
(' Respectfully submitted, i
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~~C'MC . 9L C -
Robert Guild, Esq. "-
2135 1/2 Devine Street Columbia, S.C. 29205 Attorney for Palmetto Alliance Jesse L. Riley 854 Henley Place Charlotte, North Carolina Carolina Environmental April 1, 1984 Study Group 8-
UNITED STATES OF AMERICA NUCLEAR :(EGULATORY COD 11SSION DCFORE TIE ATOMIC' SAFETY AND LICENSING BOARD In the Matter of )
Docket Nos. 50-413 DUKE POWER COMPANY, et al. ) 0-414
)
(Catawba Nuclear Station, ) April 2, 19.84 Units 1 and 2) )
~~
' CERTIFICATE OF SERVICE I hereby certify that copies of PALMETTO ALLIANCE AND CESG RESPONSES TO APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE DOCUMENTS ON BOARD CONTENTION CONCERNING CERTAIN DIESEL GENERATOR PROBLE' in the above' captioned matter has.been served upon the following by deposit in the United States mail this' 2nd day of April,1984.
James.L. Kelley, Chairman George E. Johnson, Esc.
Atomic Safety and Licensing Office of the Executive Board Panel Legal Director U.S. Nuclear Reculatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Paul W. Purdom
- Albert V. Carr, Jr., Esq.
235 Columbia Drive Duke Power Company -
Decatur, Georgia 30030 P.O. Box 33189 Charlotte, North Carolina 28242 Dr.' Richard F. Foster P.O. Box 4263 Sunriver, Oregon- 97702 Richard P. Wilson, Esc.
Assistant Attorney General State of South Carolina Chairman P.O. Box 11549 Atomic Safety and Licensing Columbia, South Carolina 29211 Board Panel U.S. Nuclear Regulatory
' Commission Chairman Washington, D.C. 20555. Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
i
Jesse.L. Riley 854 IIcnicy Plac Scott Stucky Charlotte, North Carolina.
Docketing and Service Section 28207 U.S. Nuclear Regulatory Commission Washincton, D.C. 20555 Bradley Jones, Esq.
. Regional Counsel' Den R. Willard U.S u lear Regulatory Mecklenburg County Department Commission f Environmental Health Washington, D.C. 20555 1200 Blythe Boulevard ,
Charlotte, North Carolina 2820,;
J. Michael McGarry, III, Esq.
1200 Seventeenth St., N.W.
Washington, D.C. 20036 bY ,
Rob'crt Guild, Esq t
Designates those served by overnight mail or delivery service oh -April 1, 1984.
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