ML20080E774

Response to Suffolk County Motion to Admit Supplemental Diesel Generator Contentions.Litigation of Diesel Generator Issues Recommended.Unexecuted Affidavit of Jc Kammeyer Encl

ML20080E774
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/07/1984
From:	Minton L HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080E777	List: ML20080E774 ML20080E783
References
ISSUANCES-OL, NUDOCS 8402100133
Download: ML20080E774 (67)

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1 LILCO, February 7, 1984 00CKUJO J.c w

'84 FB -9 A10:39 UNITED STATES OF AMERICA , . _ _ . , _ _, .

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY

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) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO'S RESPONSE TO SUFFOLK COUNTY'S MOTION TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS INTRODUCTION The County's proposed diesel contentions are excessive-1 ly broad. They are deliberately designed to lead to a pro-tracted, unfocused litigation of all components of all Transamerica Delaval (TDI) diesels in nuclear and marine appli-cations. Thus, they include (i) untimely matters -- matters of public record that occurred in some instances years ago, (ii) matters concerning TDI diesels of dif--

farent design at other nuclear stations with no showing of relevance to Shoreham, (iii) matters concerning TDI diesels in ma-rine and industrial applications 8402100133 840207 'E PDR ADOCK 05000322  ;

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o without regard to similarities or dis-i similarities in design, construction, maintenance or operation of those die-sels, (iv) matters raised in routine NRC and util-ity audits of TDI without regard to the substance, significance or rele'vance of the findings, (v) matters that have no bearing on the re-liable operation of the Shoreham die-sels, e.g., modifications for improved maintenance, (vi) matters without adequate basis or par-ticularization.

If admitted, these proposed contentions will lead to trying " cases within cases," i.e., trying many other collateral cases within the Shoreham diesel litigation. For example, the proposed contentions will require the parties and the Board to devote substantial discovery and hearing time to the operating, maintenance and manufacturing histories of V-16 engines in ma-rine applications, e.g., M. V. Columbia, to determine causes and remedies of various occurrences on those engines and their relevance, if any, to Shoreham's engines. The sum of these collateral cases will surely bid fair to consume more discovery time, more cost and more hearing time than all of the hearings to date before this Board.

The County's indiscriminate, lengthy lists of occur-rences or incidents involving marfae applications or engines different from those at Shoreham create only the illusion of

specificity. It is apparent from these lists that the County f

has made no good faith effort to demonstrate whether these mat-ters relate in any way to the Shoreham diesels and to the per-tinent issues of this proceeding. This is neither surprising nor accidental for the County's f'iling reflects, lamentably, that-the County's real interest lies not in whether there is reasonable assurance that the Shoreham diesels are adequately reliable. Rather, the County's real interest, manifestly, is to stop Shoreham, to prevent its opening. The proposed conten-tions reflect the County's intention to use these proceedings for that purpose.

LILCO does not oppose properly focused diesel litiga-tion designed to ascertain first (a) the diesels' adequacy for low power testing and then (b) their adequacy for commercial or full power operation. To achieve these ends, LILCO proposes that the Board, as it has in the past, rewrite the contentions to ensure a focused, efficient litigation.. More specifically, LILCO respectfully submits that on the issue of low power testing, the Board admit for litigation particularized conten-tions on specific major components.1/

1/ Based on a review of the County's contentions (see Attach-ment A), LILCO believes that the low power litigation should focus on the following components: crankshafts, pistons, cylin-der heads, intermediate push rods, turbocharger thrust bearings. Particularized contentions for these components are set forth in Attachment B. Connecting rod bearings are not in-cluded in the list because, as is shown in Attachment A, the (footnote continued)

Litigation of particularized contentions on these com-ponents would ascertain whether these items, as now installed, are adequate to perform their intended functions. LILCO be-lieves that litigation of such specific contentions plus suc-cessful completion of the much expanded and NRC Staff approved preoperational test program will provide the reasonable assur-ance of reliable diesel operation required for the issuance of a low power license.

This approach is appropriate because:

(i) it reflects and puts in proper perspec-tive the need for and function of die-sels in low power testing, (ii) it accommodates the thrust and essence of the County's concerns, and (iii) it avoids endless, unfocused litigation and ensures efficient conduct of the hearings.

Each of these points merits elaboration. -

4 This Board has already distinguished between issues that must be resolved prior to fuel load and low power testing and issues whose resolution can be sought in the longer term.

In the case of the diesels, this distinction rests in part on the fact, as the Board has noted, that the diesels (footnote continued)

County has not provided any adequate basis for a contention on these components.

1 5-l will operate for only relatively short periods (including monthly surveillance tests), even if needed for emergency service, during low power testing.

Board Memorandum and Order at 32 (June 22, 1983).

It is important to be clear that the safety signifi-cance of diesels is far less grea't during low power testing ,

than during full power operation. Although the Technical Spec-ifications require all three diesels to be available for op-eration during low power testing, there is, as a practical mat-ter, a very limited need for diesels in the fuel load and low power testing phase. Thus, at low power levels, only one of the three diesels is needed to maintain the plant in a safe conditiori in the event of loss of offsite power and a LOCA.

And even in this event, the single diesel will only be required to handle loads substantially below the 3500 KW continuous rat-ing of the engine.

It is also important to understand-the high reliability of Shoreham's offsite AC power system. First, LILCO has sig-nificant interconnection capacity (i) with the New York Power Pool through Consolidated Edison (three ties totalling 1090.MW) and (iii) with the New England power grid beneath Long Island Sound through Connecticut Light & Power (300 MW).. Second, within the LILCO system,'there are four 138 KV' circuits feeding into the Shoreham 138 KV switchyard on two separate rights-of-way. In addition to the 138 KV system, 'the Shoreham area is

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also supplied with three separate 69 KV circuits. These ar-rangements render remote a loss of off-site power to Shoreham.

Third, LILCO has taken additional measures to ensure added reliability of offsite AC power. The LILCO syst,em in-cludes ten gas turbines at Holtsville, 50 megawatts per tur-bine, two of which are equipped with automatic black start ca-pability specifically to support Shoreham. Power from these gas turbines is capable.of being supplied to Shoreham within 15 minutes through the alternate transmission lines previously de-l scribed to increase reliability.2/ Thus, even a failure of the

, (i) New York power grid, (ii) the New England power grid and (iii) the normal Laseload plants on the LILCO system would not prevent rapid restoration of offsite power to Shoreham because either of the two gas turbines with black start capability at Holtsville could supply more than enough AC power to meet all of Shoreham's needs even at full power.3/

2/ There are additional black start gas turbines east of Shoreham that are capable of supplying adequate power to Shoreham. It was these units, in fact, that restored LILCO's Port Jefferson fossil unit following the 1965 blackout.

3/ The LILCO system has experienced only one complete Elackout -- the 1965 blackout of the entire Northeast. The gas turbines at Holtsville were installed after that blackout. A recent test demonstrated that these turbines could restore. i power to Shoreham in less than 10-minutes after system  !

blackout. Also, black start gas turbines have been installed ,

at all of LILCO's major fossil stations since the 1965 '

blackout.

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Further, LILCO is also installing a 20 megawatt gas turbine on the Shoreham site with black start capability in ad-dition to the 50 megawatt gas turbine already on the site (without black start capability). The 20 MW unit is scheduled to be operational in April. Thus, even with the loss of all offsite sources, including the Holtsville gas turbines, more than adequate AC power could be provided by the 20 megawatt gas turbine on the site.4/

In summary, the high reliability of offsite AC power to Shoreham, the fact that only one of three diesel generators would be required to meet plant needs in the event of loss of offsite power at low power testing, and the fact that even this one diesel would be lightly loaded while doing so, all under-score the appropriateness of distinguishing between fuel load / low power diesel litigation issues and commercial power litigation issues.

4/ Shoreham also has redundant DC battery power supplies that permit operation of steam driven HPCI and RCIC pumps to remove decay heat in the event of loss of all AC power sources, including the diesels. LILCO has already demonstrated to the NRC Staff that Shoreham, even at 100% power, can withstand a total loss of AC power, including diesels, without sustaining any core damage for a 24-hour period. In such a scenario, the DC battery powered HPCI and RCIC systems.would continue to pro-vide the required water levels. Decay heat would be trans-mitted to the suppression pool via the safety relief valves.

See SNRC-582 dated June 15, 1982.

Next, LILCO's proposed approach to the diesel litiga-tion accommodates the County's concerns. The County's first two proposed contentions reflect a concern about the overall d,esign of the Shoreham diesels.5/ LILCO's proposed approach reaches this concern through the litigation of the adequacy of specific components. For example, litigation of the adequacy of the 13" x 12" crankshaft must include whether it is under-

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sized, i.e., whether its design is adequate for the forces and stresses it experiences given the rating of the diesel. If the record warrants the conclusion that the 13" x 12" shaft is ade-quate to perform its function, then the concern over design of this component, the concern that it may be undersized.or over-rated, will have been resolved.

The same is true for the other major components. Thus, litigation focused on the causes of the observed piston cracks will necessarily consider, for example, whether the design of the original Shoreham AF pistons caused or contributed to the observed cracking and whether the new AE piston design elimi-nates this concern.

Nor is the County's frequent reference to the interac-tion of all diesel components a bar to LILCO's approach. Of course, there is interaction among the components, and this 5/ The contention that the diesels are overrated and under-sized is essentially a design concern.

obvious fact must be, and is, taken into account in the ap-proach suggested here. In the case of the crankshaft, for ex-ample, it is plain that the forces and stresses on the crank-shaft are a function of the operation of other components (e.g., piston firing pressures) and transmitted to the shaft through other components (e.g., connecting rods and connecting rod bearings). It is equally plain that FaAA accounted for this interaction in its analysis of the crankshafts and that a properly focused litigation of the adequacy of the 13" x 12" crankshaft would also cover this. Calculations of crankshaft stresses are in essence calculations of the crankshaft's re-sponses to the forces exerted on it by other components with which it interacts. Interactions, then, are accounted for in LILCO's assessment of the adequacy of each component. In short, the County's vague allusions to "interactivity" or I

" interrelationship" among all the diesel parts are mere obscur-antism and no bar to LILCO's proposed approach.

LILCO recognizes that the County's de-sign / undersized / overrated concern is not limited to the indi-vidual component occurrences that LILCO proposes should be lit-igated for the low power phase. Rather, LILCO understands that the County contends that the individual occurrences, even though remedied, raise questions about the overall design.

This more general concern is addressed by LILCO's performance

of the Design Review and Quality Revalidation (DRQR). As the Board knows, LILCO committed to a complete review of the design and quality of the Shoreham diesels in November, 1983.

LILCO's DRQR is a comprehensive program aimed at ascer-taining the reliability of the Shoreham diesel generators through reviews of the designs and quality attributes of most of the engine components. As part of the DRQR, every component has been reviewed to determine its function and potential con-tribution to engine reliability. Included in this review was an assessment of the nuclear and non-nuclear experience with these components. From this revicw, 171 out of the total of 218 component types on the Shoreham diesels were selected for further evaluation. Design review and quality revalidation teams are currently performing appropriate design analyses, calculations, inspections, nondestructive examinations and, where necessary,' destructive testing to confirm, independently of TDI, the adequacy of each component's design and quality.

At this time over 100 engineering and technical personnel from LILCO, SWEC, FaAA and other consultants are currently engaged in this effort.6/

6/ The County, in early January, was furnished with a DRQR program description, copies of DRQR procedures and a list of the component types to be reviewed. This program is essential-ly the same program as that presented by the Diesel Generator Owners Group to the NRC Staff on January 26. The NRC Staff has accepted this program as an appropriate framework for resolving TDI diesel generator issues.

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The DRQR is not scheduled for completion until approxi-mately April 1, 1984, and LILCO does not think that hearings aimed at a low power license should or need cover the large number of components (171 component groups) and issues involved in the DRQR. LILCO believes that the prior extensive preoperational test program plus its new, enhanced preoperational test program will ensure that any problems that might affect diesel operation during low power testing will be identified. Successful completion of the test program and. lit-igation of known conditions on the major components is suffi-cient to provide adequate assurance that the diesels will per-form any low power testing function. Of course, the County and Staff will have access to the results of the DRQR and may seek to pursue additional design concerns later, if appropriate.

i LILCO's proposed approach also accommodates the Coun-ty's last two concerns, manufacture and quality assurance. ,

1 Again, litigation of specific conditions on the major compo-nents, as LILCO suggests, certainly encompasses quality and manufacturing matters. For example, litigation of the cylinder head issue will involve specific questions concerning the de-sign, manufacture and quality of the cylinder heads. In this regard, it is important to note that all three Shoreham diesel generators were disa'ssembled, inspected and^ reassembled by LILCO; thus many concerns about TDI's QA programs may not now be relevant.

Again, LILCO recognizes that the County's manufacturing and QA concerns extend beyond the reported occurrences to cast doubt on the entire TDI program. These concerns are addressed by the DRQR program; it is designed to verify key quality attributes independently of the TDI program.7/ Again, however, LILCO does not consider that litiga' tion aimed at fuel load and -

low power testing should be delayed pending completion and re-view of the entire DRQR. Such litigation should more appropri-ately focus, as LILCO suggests, on the adequacy of design,. man-ufacture and quality of specific major components in light of

' specific findings or occurrences at LILCO.

Finally, considerations of efficiency and conservation of Board and party resources also militate strongly in favor of LILCO's approach. Litigation of specific design manufacturing and quality aspects of specifically identified problems with certain major components is the correct approach for litigation leading to a low power license. In sharp contrast, admission 7/ While quality issues could also be resolved by litigation concerning the details of TDI's QA program as they relate to Shoreham, LILCO believes such an exercise-(requiring inquiry into 10 year old audits, inspections and the like) would be time-consuming, unproductive and neither efficient nor particu-larly probative. In LILCO's view, a far more productive-and probative means of addressing quality and manufacturing con- l cerns is to focus on the diesel engines as they are'now, after disassembly, inspection and reassembly by LILCO, and,.as in the DRQR, to verify various key quality attributes by appropriate means, including inspections, nondestructive testing and de-structive testing, where appropriate.

l of the County's excessively broad and open-ended proposed con-tentions would likely lead to burdensome and unnecessary dis-covery and unduly lengthy depositions and hearing.

In summary, therefore, LILCO's proposal for focused litigation of particularized contentions for specific compo-nents is appropriate because (i) it correctly recognizes the distinction between low power and full power issues; (ii) it adequately addresses the County's legitimate concerns and (iii) it ensures efficient hearings and avoids the protracted litiga-tion certain to accompany the County's proposed contentions.

Legal Principles The pertinent legal standards for judging the admissi-bility of late filed contentions were addressed in the Board's Memorandum and Order dated June 22, 1983. Memorandum and Order at 1-17. Consequently, a discussion of those standards is un-necessary. LILCO will proceed to its views on the County's new diesel contentions.

In summary, LILCO believes that:

1. The County may litigate questions concerning the overall design (including whether the machines are overloaded or undersized), manufacture and quality of the Shoreham diesels in the manner suggested by LILCO on pages 8-12 above.

2. For reasons discussed in Attachment A, the County 1

may litigate only specific contentions concerning the following.

. specific diesel generator components. j 1

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(a) crankshafts, (b) pistons, (c) cylinder heads, (d) intermediate push rods, and (e) turbocharger thrust bearings.

3. -The County also may litigate as a long-term, post fuel load issue the vibration contention already admitted by the Board. Memorandum and Order at 32-33 (Tune 22, 1983). The County has not provided any additional new information which would justify changing the Board's prior ruling on this matter.

4. With respect to the litigability of the specific diesel generator issues raised in the County's contentions, LILCO believes that the timeliness factor should be control-ling. Given the massive number of items listed in the County's contentions, it is , impractical to analyze in detail the five factors that must be considered under 10 CFR S 2.714(a)(1) for each item. Rather, this analysis can be simplified by some i

general observations.

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(a) Based on the Board's analysis of the Coun-ty's diesel contention filed in May, 1983, LILCO concludes that the Board is likely to find that factors (ii), (iii) and (iv) would generally weigh in the County's favor. This is not LILCO's view, but, for reasons stated below, it is unnecessary l to pursue arguments in this regard.

(b) Factor (v), the extent to which the County's participation will broaden the issues or delay the proceeding, will always weigh against the County. Each specific issue ad-mitted by the Board broadens the scope of the proceeding and certainly will delay its completion. Also, since the Shoreham plant is now complete except for diesel generator testing, ad-ditional diesel issue; will delay fuel load and low power op-eration of the plant.

(c) Given (a) and (b) above, and the importance of the timeliness factor 8/ in performing the balance required by S 2.714, the question of timeliness should be controlling in passing on the admissibility of individual issues unless it ap-pears that special circumstances exist.

l (d) Finally, the County must meet the require- '

ments applicable to all contentions whether timely or late 1

filed. They must be relevant, adequately particularized and have an adequate basis.9/

8/ Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-743, slip. op. at 17, 27-29 (Sept. 29, 1983);

Duke Power Co. (Perkins Nuclear Staticn, Units 1, 2 and 3),

ALAB-431, 6 NRC 460, 462 (1977); Virginia Electric and Power Co. (North Anna Station, Units 1 and 2), ALAB-289, 2 NRC 395 (1975).

9/ Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), slip op, at 2-4 (April 12, 1983); Pacific Gas &

Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-81-5, 13 NRC 361, 364 (1981). Maine Yankee Atomic Power Co. (Maine Yankee Atomic Power Station), LBP-82-4, 15 NRC 199, 206 (1982); Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20-21 (1974).

I LILCO has applied these standards to each paragraph of l l

the County's four contentions. The results of this analysis are included in Attachment A. As noted, LILCO does not dispute that problems identified with TDI diesels raise questions con-cerning the overall design, manufacture and quality of the Shoreham diesels beyond the specific problems experienced at Shoreham. Indeed, the Company took steps in October, 1983 to develop the DRQR to resolve these concerns. In LILCO's view, however, fuel load and low power litigation require only liti-gation of particularized contentions relating to specific key

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components and successful completion of the enhanced preoperational test program. Moreover, no reason exists to litigate specific alleged problems unless the County shows in an adequate and timely fashion that the problem remains uncorrected. Also important is that while diesel generator problems at other nuclear and marine diesels should not be lit-igated at Shoreham, these events will be considered in evaluating the Shoreham diesels. In the DRQR program, all available data, including Part 21 and 50.55(e) reports concern-ing other nuclear utilities, as well as data from marine appli-catione, will be considered in asse_ssing the design and quality of the engines.

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Conclusion For all of the reasons stated above, LILCO urges the Board to accept LILCO's proposal for litigation of diesel gen-erator issues for Shoreham.

i Respectfu,lly submitted, LONG ISLAND LIGHTING COMPANY t

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. Taylor Reveley, ~III T. S. Ellis, III Anthony F. Earley, Jr.

Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: February 7, 1984 1

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ATTACHMENT A LILCO'S RESPONSE TO SUFFOLK COUNTY SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS CONTENTION I.A.

Paragraph 1. The County claims that the replacement crankshafts currently installed in the diesel generators are inadequate. LILCO does not object to litigating the adequacy of the replacement crankshafts. '

Paraq'raph 2. LILCO objects to the admission of this portion of the contention because there is no basis for the County's conclusion that the increased weight of the new crank-shafts will cause " excessive wear" on the main bearings. The new crankshaft weighs less than 5% more than the old crank-shafts. Moreover, past experience has not indicated any exces-sive main bearing wear. See Kammeyer Affidavit at 2.

Paragrapn 3. This contention incorrectly staras that there was a 96% failure rate for the Shoreham pistons. None of the cracked- pistons found at Shoreham had failed nor did the cracked pistons prevent operation of the diesels. In any event, LILCO does not object to litigation of a' properly particularized contention concerning the pistons on the Shoreham diesels. The County claims that the-replacement model AE pistons are of-an " inadequate design" to withstand operating conditions. There is insufficient basis to support such a

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l generalized claim. Rather, the Board should only admit a pis-ton contention that focuses on actual deficiencies that have been identified in the ortginal Shoreham pistons. Thus, the contention should address whether the new model AE pistons are of an adequate design and manufacture to prevent piston failure due to cracking in the area of the crown to skirt connecting bolts.

Paragraph 4. LILCO does not object to litigation of the adequacy of the design and manufacture of the replacement cylinder heads at Shoreham.

Paragraph 5. This portion of the contention is hope-lessly vague and therefore fails to meet the particularization requirements for contentions in NRC proceedings. For example, the contention fails to specify the " interrelationships" to be litigated or the " major components" that have " weaknesses" that may be exacerbated by the unspecified interrelationships. In LILCO's view, where relevant interrelationships between various components of the Shoreham diesels exist, they should be taken into account in the individual component analyses. For exam-ple, in the course of litigating the adequacy of the replace-ment crankshafts, LILCO will demonstrate that all of the perti-nent forces on the crankshaft, given the current design and rating of the engines, have been considered. Consequently, the paragraph should not be admitted as a separate contention.

CONTENTION I.B.

Paragraph 1. The County fails to provide an adequate basis for this contention. First, Professor Christensen's statement that exhaust temperatures in the range of 1100* F are excessive is unsupported and une:tplained. He provides no basis for the conclusion nor does he indicate what effects such an exhaust temperature will have on the engine. As the attached affidavit refl5 cts, Professor Christensen's factual assertions are not accurate. Kammeyer Affidavit at 2. Moreover, this I portion of the contention is too vague to be acceptable since it does not put the parties on notice of precisely what would be litigated if admitted.

Paragraph 2. LILCO objects to the admission of this contention because the County has failed to establish an ade-quate basis to show that the de-rating of an Alaskan ferry boat is relevant to the Shoreham engines. The County has not ad-dressed a number of important factors crucial to determining whether the Columbia de-rating is applicable to Shoreham: (1) the engines on the M. V. Columbia are V-16 engines while the Shoreham engines are straight 8 diesels; (2) the Cotumbia en-gines may have used heavy fuel while the Shoreham engines use light diesel fuel; (3)~ the Columbia engines are variable speed marine engines rather than constant speed stationary engines:-

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(4) the maintenance applied to the Columbia engines and the Shoreham engines may be significantly different; (5) the op-erating loads or operating histories of the engines may be sig-nificantly different, and (6) the QA applied to the engines may be significantly different. Moreover, the County failed to disclose significant information to the Board by citing only the " Seaworthy Report" as a basis for this and other conten-tions related to occurrences on the M. V. Columbia. Another report done for the State of Alaska (" Sharp Report"), not men-tioned by the County, contradicts many of the findings in the

" Seaworthy Report."l/ In fact, with respect to this particular contention, the " Sharp Report" suggests that the de-rating of the M. V. Columbia engine was done for economic reasons.2/

Consequently, there is not an adequate basis for admitting con-a tentions in the Shoreham proceeding based on occurrences re-ported on the M. V. Columbia. Similar considerations justify 1/ This highlights LILCO's view that admission of contentions based on matters arising out of marine applications will result in litigation of many cases within the Shoreham case.

2/ George C. Sharp, Inc., Overview of Reports, Analysis and Recommendations Regarding Main Propulsion Engines M/V Columbia, V l-2 (July 26, 1983). De-rating allows the owner to increase maintenance intervals and thus have greater engine availabili-ty. This is an important consideration for engines that oper-ate continuously for extensive periods of time. As the Board knows, the Shoreham engines will be used, even under emergency conditions, for only short periods of time.

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rejection of contentions concerning matters related to other marine engines.

Admission of this contention would improperly focus litigation on the Columbia engines rather than on litigation of i the reliability of the Shoreham engines. It is well to note that exclusion of this contention does not mean that problems identified on the M. V. Columbia or any other TDI engine will not be considered for Shoreham. LILCO's DRQR is designed to review all available operating experience from TDI engines,in both nuclear and non-nuclear applications. This program will determine whether this operating experience is applicable to Shoreham and, if so, whether any corrective actions are appro-priate.

Paragraph 3. This contention is without basis. As LILCO's vibration study (appended to ,the Diesel Generator Oper-ational Review Report provided the Board and parties in July, i 1983) indicates, vibration levels at Shoreham were consistent with vibration levels at other similar TDI engines. Signifi-cantly, the engine at Lincoln, Kansas operated at a lowcr speed (400 RPM vs. 450 RPM), and a lower power rating (2500 KW vs.

3500 KW). Therefore, there is no basis for the County's asser-tion that the baseline vibration of the Shoreham engines is ex-cessive or that Shoreham's power rating adversely affects vibration.

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In any event, the Board admitted a vibration contention in June, 1983 for long-term resolution. The County offers no additional evidence or basis to support changing this conten-tion from a long-term issue to a low power license issue.

Thus, it should remain a post-fuel load / low power issue.

CONTENTION II.A.

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Paragraph 1 LILCO objects to this portion of the con-tention because the County has not provided an adequate basis

, to support its statement that the deficiencies identified in connecting rod bearings have been only " partially" remedied.

FaAA's final report on the connecting rod bearing failure, at-i tached for the Board's convenience, indicates that the replace-ment connecting rod bearings have a predicted life of 38,000

hours. Given the intermittent use of diesel generators in nu-clear standby service, the present bearings should last for the life of the plant.3/ In addition, the County provides no basis for its vague claim that the replacement connecting rod bearings "will not ensure correct lubrication and freedom from problems." .

3/ It is worth noting that.the cracking found in the original

connecting rod bectings had not prevented operation of the die-sels.

Paragraph 2. LILCO objects to the admission of this portion of the contention because the County has failed to pro-vide an adequate basis for it. As noted in the FaAA jacket water pump inspection document cited by SC and attached to this response, the scor'ing indications found on the jacket water.

pump for emergency diesel generator 102 were caused by the crankshaft failure in this diesel generator. The jacket water pumps for the other two diesel engines were inspected and did not exhibit similar problems. Thus, the reference to the FaAA document provides no basis to conclude that the jacket water pump scoring is anything but a ccusequential result of the crankshaft failure. The County's reference to a July 20, 1983 f

Part 21 report similarly fails to provide any adequate basis for this contention. The condition reported in thir Part 21 report had been previously reported to the NRC by LILCO in a 10 CFR S 50.55(e) report (SNRC-777) dated October 15, 1982. Thus, any attempt to litigate this issue is also untimely.

Paragraph 3. In support of this portion of the conten-tion, the County relies upon a LILCO S 50.55(e) report dated May 4, 1983 (SNRC-883). The County-attempted to raise this issue when it moved to reopen the record for consideration of diesel generator issues in May, 1983. The Board previously ruled that:

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i the only remaining triable significance of the bolt issue is its possible connec-tion with the vibration contention, and it may be considered under any paragraph 2 litigation.

Memorandum and Order,at 34 (June 22, 1983).4/ The County has presented no reasons to change the Board's dispos'ition of this issue.5/

Paragraph 4. The County attempted to raise this issue when it moved to reopen the record in May, 1983. Memorandum and Order at 27-28 (June 22, 1983). The issue was also dis-cussed in the Diesel Generator Operational Review Report (July, 1983). Since the County provides no additional information, the County's attempt to revisit this matter now is untimely.

Paragraph 5. LILCO objects to the admission of this portion of the contention because it is not timely. The County relies on a 10 CFR Part 21 report dated May 13, 1983.

4/ The Board also directed the parties to discuss possible inspection of rocker arm bolts. Id. at 34-35. Attached is a September 22, 1983 letter from T. S. Ellis, III to Messrs.

Goddard and Dynner in which LILCO describes the additional in-spections performed on the rocker' arm shaft bolts.

5/ The County's statement that the design changes in the rocker arm assembly capscrews may overstress the cylinder head subassembly is without any stated basis. Moreover, this point is untimely because it could have been raised when the County moved initially to reopen the record.

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Moreover, this matter was discussed in the Diesel Generator Op-erational Review Report provided to the County in July, 1983.

The County has provided no new information that would justify admission of this portion of the contention.

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- Paragraph 6. This portion of the contention should not be admitted because the County provides no basis to conclude that the condition reported in TDI's September 27, 1983 Par'c 21 report has not been remedied. As the attached affidavit re-flects, this report dealt with cable connected to the electri-cal overspeed trip. This cable has been replaced by qualified i cable for the Shoreham engines. Kammeyer Affidavit at 3.

Paragraph 7 The County has failed to provide any basis to support its claim that the pitting (or as the County calls it, exfoliation) on camshaft lobes of diesel generator 101 is evidence of improper design. First, LILCO inspected the other camshafts and found no similar conditions. Second, as the attached affidavit reflects, the camshaft pitting had.no effect on the operation of the DG 101. Nor would there have been any long-derm effect on diesel reliability since the cam-shaft is inspected periodically and replaced if any observed pitting threatens to hinder engine operation. In any event, LILCO replaced.the affected camshaft lobes. Kammeyer Affidavit

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at 3.

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Paragraph 8 LILCO does not object to litigation con-cerning the prelubrication system for the turbocharger thrust bearing. Although this contention is based on a 1981 5 50.55(e) esport, recent developments during the preoperational test program at Shoreham indicate that there may be a basis for concern about the turbocharger thrust bearing. On February 1, 1984, diesel generator 101 was noted to have low turbocharger thrust bearing oil pressure. Upon investigation, it was deter-mined that the turbocharger thrust bearing had failed. On ,

February 5, 1984, a failure occurred on the turbochacger for diesel generator 103. LILCO has advised the NRC that these failures are potentially reportable pursuant to S 50.55(e).

LILCO's investigation of this matter is continuing.6/

Paragraph 9. As the attached affidavit reflects, all of the tube runs on the Shoreham diesels have since been evalu-ated and modified as appropriate for proper suppcrt. There have been no recurrences of this condition. Kammeyer Affidavit '

at 3-4. The County does not provide any basis to support a 6/ In this regard, it is well to recall that the purpose of preoperational testing is to identify and correct problems and the program can be expected to disclose other discrepancies in the future. But LILCO does not believe that every such dis-crepancy should be litigated in this proceeding. In this in-stance, however, because of the prior Part 21 report relating to the turbocharger thrust bearings, LILCO cannot, at this time, object to litigation of this issue.

contention that this condition has not been remedied. Thus, this contention should be litigated, if at all, in the context of the long-term vibration issue. Memorandum and Order at 32-33 (June 22, 1983).

Paragraph 10. LILCO objects to this contention because it la noc supported by an adequate basis. The indications end cracks found in the baseplates of diesel generators 102 and 103 were identified by LILCO in the cotese of the disassembly of those diesel generators. The December 7, 1983 FaAA memorandum referenced by the County (attached) ntates that the cracks and indications in the baseplate of diesel generator 102 were at-tributable to the crankshaft failure on that machine. The mem-o.andum also indicates that the cracks and indications on the baseplate of diesel generator 103 were not caused by the op-eration of the diesel. FaAA evaluated the cracks and indica-tions and determined that they will not affect operation of the diesels. The County has provided no information to the con-trary and thus provides no basis to support a contention con-cerning the adequacy of the base plates.7/

7/ L1LCO has very recently received a TDI failure analysis on the base plates dated February 1, 1984. A copy will be ser3 to the County under separate cover. TDT concludes that the indi-cations are non-relevant grain bcundaries of compacted graphite and that the bases are functionally acceptable.

9 4

Paragraph 11. LILCO objects to this contention because the County has provided inadequate basis to support its claim of defective design. The cited memorandum indicates that im-proper installation was the likely cause of the failure.

Kammeyer Affidavit at 4.

Paragraph 12 LILCO objects to this contention because the County provides inadequate basis to support a contention that the cylinder liners are defectively designed. Although pitting occurred in three cylinder liners, there is no basis to support a conclusion that this pitting was caused by inadequate design. As the McHugh letter cited by the County reflects, TDI i attributes the pitting to faulty operation of the injector tips. As the attached affidavit indicates, it is not unusual

< to replace cylinder liners as part of a normal maintenance pro-gram. Although LILCO did replace the three liners, they were still useable. Kammeyer Affidavit at 4.

Paragraph 13. This paragraph of the contention at-tempts to sweep into the litigation a laundry list of product improvements or modifications made during the course of tne in-stallation of the Shoreham diesels. The County has made no at-tempt on any of these items to show the basis for a conclusion that the modification represents a design deficiency.. Nor does the County attempt to show that the changes are unusual in type

. or number from that expected during the installation and testing of any large component. Indeed, modifications or im-provements to the diesel generators are not probative of defec-tive design. This paragraph of the County's contention at-tempts to create the illusion of specificity by submitting a list of modifications but the list reflects instead only the lack of any good faith effort by the County to focus on impor-tant concerns. For example, item (b) appears on its face to suggest that the modification was made to facilitate mainte-nance. In fact, the modification was made to permit removal of the diesels from the diesel generator rooms for crankshaft re-placement. Kammeyer Affidavit at 4-5. By no stretch of the imagination does this have anything to do with diesel design.

Similarly, items (f), (h) and (i) also were made to improve maintenance requirements. Kammeyer Affidavit at 4-5. Finally, item (g) deals with a recommendation for additional protective circuitry for the diesels beyond the already extensive control systems provided. In short, the County has provided no basis for concluding that the modifications listed reflect inadequate l design.

CONTENTION II.B.

This portion of the contention alleges that deficiencies identified at TDI diesel generators at other i

1

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nuclear plants demonstrate that the Shoreham diesels have been inadequately designed. This section assumes that TDI diesel generators at other nuclea: plants are " essentially identical or similar to the EDG's [at Shoreham]." While there are simi-latities among the various TDI engines, the relevance of a failure of a component on another diesel generator must be ex-amined on a case-by-case basis. Thus, fot example, occurrences ,

on the V-16 engines at Grand Gulf or Perry must be analyzed to determine their applicability to Shoreham. Some V-16 engine components are markedly different in size or design (e.g., con-necting rods and crankshafts) and various forces and stresses in that engine may differ substantially from those experienced in the Shoreham engines. Despite this, the County has provided no basis in any of the paragraphs in this portion of the con-tantion for the Board to conclude that the occurrences at other l

locations apply to Shoreham.

Paragraph 1. If the County intends to litigate the de-tails of the spherical washer failures reported in this November 5, 1981 Part 21 report and the Grand Gulf 10 CFF.

50.55(e) report dated April 15, 1982, it is grossly out time. This condition was also discussed ~in the Diesel Genera-tor Operational Review Report provided to the County in early July. The County omits to mention some pertinent facts:

spherical washers are not used in the AE pistons now installed at Shoreham, nor were they used in the modified AF pistons in which the cracks were found. As already noted, LILCO does not l

object to the litigation of the piston cracking problem found at Shoreham. Thus, the condition described in this paragraph can be considered as part of the background information relating to the piston contention.

Paragraph 2. LILCO objects to this contention. (1) It is untimely because it is based on a December 9, 1981 Part 21 report. (2) It is irrelevant because the condition reported was not applicable to Shoreham. Kammeyer Affidavit at 5.

Paragraph 3. The condition reported at Grand Gulf, which did not prevent these engines from operating, has not been found at Shorency Nonetheless, because the Shoreham and Grand Gulf engines have intermedia".e push rods in common, LILCO has ordered intermediate push rods of a new design. LILCO does i

not object to liti>3ation of this issue.

Paragraph 4. LILCO objects to this contention because the County provides no basis to conclude it is applicable to l i

Shoreham. Moreover, the Board has already admitted a long-term '

vibration contention for Shoreham. '

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Paragraph 5. LILCO objects to the admission of this contention because the County provides no basis to conclude that it is a design deficiency or that it is applicable to Shoreham. In fact, the Shoreham diesels have had an excellent air start record. Diesel Generator Operational Review Report at 9.

Paragraph 6. LILCO objects to the admission of this contention. (1) It is irrelevant; Shoreham uses Class IE power for diesel generator control circuits. (2) There is no basis to conclude that the problem at Perry was attributable to TDI.

Kammeyer Affidavit at 5.

Paragraph 7 LILCO objects to this contention because the County fails to provide any basis to conclude that a design defect is in"volved. In addition, LILCO has already taken steps to ensure that the problem at Grand Gulf does not occur at Shoreham. Kammeyer Affidavit at 6.

Paragraph 8. LILCO objects to this contention because it is irrelevant to Shoreham. The fuel oil line arrangement at Grand Gulf is different from the fuel oil line arrangement used at Shoreham. Kammeyer Affidavit at 6.

I Paragraph 9. LILCO objects to this contention. (1) It is untimely because it is based on Part 21 and S 50.55(e)

i reports that were issued almost two years ago. (2) It is ir-relevant because the condition identified in the reports is not applicable to SNPS. Kammeyer Affidavit at 6.

Paragraph 10,. LILCO objects to this contention; it in-volves the same concerns raised in contention II.A.6. Kammeyer Affidavit at 3.

Paragraph 11. LILCO objects to this contention. .( 1 )

It is untimely because it is based upon a September 19, 1980 Part 21 report. (2) It is irrelevant because the Shoreham die-sels do not have the link rod assemblies that are used on "V" engines. Kammeyer Affidavit at 7.

Paragraph 12. LILCO objects to this contention. (1)

It is untimely because it is based upon Part 21 and S 50.55(e) reports that are over a year old. (2) The issue is irrelevant to Shoreham. The Catawba flexible drive coupling used an isoprene material which deteriorated. The Shoreham flexible drive coupling is made of neoprene which will not deteriorate rapidly. Kammeyer Affidavit at 7.

Paragraph 13. LILCO objects to this contention because it fails to provide any basis to conclude that the generator at Shearon Harris is made by the'same manufacturer and is of the same design as the Shoreham generator. At a minimum, the Sheaton Harris diesels were purchased to different specifica-tians. Moreover, the contention is vague in that it purports to include unspecified " dimensional, electrical and specifica-tion deficiencies."

Paragraph 14. LILCO objects to this' contention. (1)

It is untimely because it is based upon a November 5, 1981 Part (2) It is irrelevant because Shoreham uses differ-21 report.

ent check valves and thus the condition described in that Part 21 report is not applicable to Shoreham. Kammeyer Affidavit at 10.

Paragraph 15 LILCO objects to this contention. (1)

It is untimely because it relies on a February 1, 1982 5 50.5S(e) report. (2) It is inapplicable to Shoreham because Shoreham's pneumatic logic is of a different design than Grand Gulf's. Kammeyer Affidavit at 7.

Paragraph 16. LILCO objects to this contention. (1)

It is untimely because it relies upon a Grand Gulf August 9, 1982 S 50.55(e) report concerning a relay tachometer. (2) The' County provides no basis to conclude that it is applicable to Shoreham.

CONTENTION II.C.

LILCO objects to the admission for litigation in the Shoreham proceeding the problems listed in this section. These matters are based on occurrences on marine diesel engines.

For the reasons stated in response to Contention I.B.2 above, they should not be admitted by the Board.

CONTENTION III.A.

Paragraph 1. Questions concerning the manufacture of the cylinder heads should be litigated in the context of the already admitted cylinder head contention.

Paragraph 2. LILCO objects to this contention because it has inadequate basis. SC claims that the "[f}ailure of the connecting rod bearings was caused in part by voids due to im-proper manufacturing techniques," citing as a basis FaAA's in-terim (10/31/83) and final (12/5/83) reports on the bearings.

Although the interim report lists the voids as a potential cause, the final bearing report indicates that subsequent anal-ysis showed that the voids were not atypical of cast aluminum bearings and that in the absence of abnormally high stresses they would not be detrimental to bearing life. Moreover, the final report predicted a 38,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> bearing life for the new connecting rod bearings, well in excess of the number of hours likely to be put on the diesels during the 40 year life of the Shoreham plant. The County has asserted no basis for challenging this conclusion.

Paragraph 3. Any manufacturing defects which contrib-uted to the piston cracking obser~ved at Shorenam should be lit-igated as part of the piston contention. LILCO notes that the documents cited by the County do not support its claim that manufacturing defects caused the conditions found at Shoreham.

Paragraph 4 See LILCO's Response to II.B.8 above.

Paragraph S. LILCO objects to this contention because it is without adequate basis. First, the generator was manu-factured by Parsons-Peebles, not TDI. (A copy of the failure analysis is attached.) Second, a letter from the manufacturer

%l (attached), of which the County was aware, indicated that the problem was an isolated occurrence. Consequently, there is in-sufficient basis to admit a contention on this issue.

Paragraph 6 LILCO objects to this contention. LDR 1642 and the "McHugh lotter" cited by SC indicate that the groove on the liner was a machining mark of no significance.

As the McHugh letter states, the groove was on the outside of the liner and, thus, would have no effect on piston operation.

In addition, the letter indicates that'the groove had been

noted during the installation inspection and was deemed accept-able. Thus, the County has provided insufficient basis to sup-port its allegation that the mark was caused by " improper ma-chine shop processes." The County alsb has not provided any basis to indicate that this condition co,uld have any effer on diesel operation.

Paragraph 7. LILCO objects to this contention. The County was aware of the cracked subcover assemblies prior to tae crankshaft failure. The County made no effort to raise the issue at that time. Moreover, the documentation cited by the County does not support a contention because it indicates that the cracks in the subcover assembly were in a nonsupporting member and thus had no impact on diesel operation.

Paragraph 8. LILCO objects to this contention because the County has not provided an adequate basis to litigate the issue. The memorandum cited by the County indicates that the cylinder head nuts in question would fail, if at all, only when being torqued during installation. Thus, the condition has no impact on operation since nuts that do not fail during torquing will not fail during operation. Kammeyer Affidavit at 7-8.

Paragraph 9. LILCO objects to this contention because the County has not provided an adequate basis to litigate the issue. The condition noted was found and corrected in the not-mal course of LILCO's initial check-out program. Kammeyer Af-fidavit at 8. The County has not provided information which suggests anything to the contrary.

Paragraph 10 LILCO objects to litigation of this issue for the reasons stated in response to Contention II.A.7.

Paragraph 11. LILCO objects to the litigation of this issue because the County has failed to provide an adequate basis for the admission of a contention. The paragraph refers to injector tips that were allegedly improperly designed but the reports cited, which deal with connecting rod bearings, do not mention injector tips.

Paragraph 12. LILCO objects to this contention, which incorporates by reference the items covered in Contentions II.A.9, 10 and 12, for the reasons stated in LILCO's responses to those items. .

CONTENTION III.B.

See LILCO's general comments on Contention II.B above.

Paragraph 1. The condition identified in the Part 21 report cited by the County is inapplicable to Shoreham. That report involved the heat treating of certain AN type pistons.

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1 .

LILCO originally used type AF pistons and now has installed AE type pistons. In any event, the role of residual stresses on piston cracking may be litigated as part of the piston conten-tion.

Paragraph 2 See LILCO's response to Contention II.B.1 above.

Paragraph 3. LILCO objec*.s to this contention. (1) It is untimely because it is based upon a July 30, 1981 Part 21 report. (2) It is irrelevant because the condition identified i i

is not applicable to Shoreham. Affidavit at 8.

Paragraph 4. This paragraph incorporates by reference the items listed in Contention II.B.1, 4, 7, 8 and 14. LILCO's response to II.B.1 indicates that this concern should be liti-gated as part of the piston contention. With respect to the balance of the !.tems, LILCO objects to them for the reasons stated in the corresponding paragraphs of LILCO's response to Contention II.B.

CONTENTION III.C.

LILCO objects to the admission of this section of Con-tention III for the reasons stated in response to Contention I.B.2 above.

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CONTENTION IV In essence, this contention alleges that the Shoreham diesels (including components and replacement components) were not manufactured undet a properly implemented Appendix B QA program at TDI. Consequently, the County concludes that LILCO must replace the engines with non-TDI engines. This County contention, however, is structured in a way which invites vir-tually endless litigation on the issue. LILCO's views on the most productive approach to diesel QA matters are set out in LILCO's Response.

Unquestionably, TDI has an Appendix B QA program in ef-fect.8/ The heart of SC's claim is that the program was not

" effective" or properly implemented. LILCO disagrees with the County'c view but does not believe that it would be productive to litigate the implementation of the TDI program as reflected, inter alla, in 10 year old audits, inspections and findings.

Moreover, such an inquiry might not be particularly probative given that the TDI engines were disassembled, inspected and 6/ The County, for quite some time, has had documentation relating to LILCO's initial review and approval of TDI's Appen-dix B program. Thus, the County did not challenge the exis-tence of an Appendix B program. Moreover, the fact that more than ten other nuclear utilities bought TDI diesels for nuclear service and that the NRC has been auditing the TDI program for a number of years indicate that there was and is an Appendix B program in place at TDI.

l I

-f rebuilt at Shoreham under LILCO's QA program. Since the ulti-

, mate purpose of any diesel QA litigation would be to demon-strate that the quality of the diesels is adequate to ensure safe and reliable operation, LILCO's proposal to litigate the adequacy of specific components coupled with completion of the test program accomplishes this goal for fuel load and low power testing. The DRQR addresses the issue for operation beyond low power testing.

The following discussion gives LILCO's position on the litigability of the specific QA concerns raised in Contention i

IV.

CONTENTION IV.A.

To the extent contentions concerning a component contained in Contentions I, II or III are admitted for litiga-tion, appropriate quality attributes for that component would be addressed.

CONTENTION IV.B.

Paragraph 1. LILCO objects to litigation of this issue. (1) It is untimely because it is based, in part, upon S 50.55(e) reports that are more than a year old; one report is almost two years old. (2) The issue is not relevant because l

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._ .. . _ .. .- =. . ._.

a the Shoreham diesels were not required nor were they purchased to meet ASME III requirements. (3) The County has provided no basis to conclude that Shoreham's pipe welds violated the ap-plicable requirements. Kammeyer Affidavit at 8-9.

e Paragraph 2 LILCO objects to the litigation of this issue because there is no basis to conclude that it is not re-solved. The purpose of the cam gear bolts is to ensure that the cam gears remain in their proper orientation so that engine timing is maintained. Wher. this condition was dicovered, en-gine timing was verified sad the bolts were installed.

Kammeyer Affidavit at 9.

Paradraph 3. LILCO objects to tne litigation of this issue because there is no basis to conclude that the condition has not been corrected. When the condition was discovered, the engine governor drive was repaired and aligned. Kammeyer Affie davit at 9.

Paracraph 4. LILCO objects to this paragraph because there is no basis to conclude that any QA deficiency was in-volved. Kammeyer Affidavit at 9. Moreover, this paragraph is untimely because the cranksnaft thrust clearance problem was noted in the Diesel Generator Operational Review Report provid-ed to the County in early July, 1983.

Paragraph 5. LILCO objects to this contention. (1) It is untimely because it is based on a 1980 5 50.55(e) report.

(2) It is irrelevant because Shoreham does not have any battery racks associated with the diesel generators. Kammeyer Affida-

. vit at 10.

Paragraph 6 LILCO objects to this contentior- (1) It is untimely because it is based on a 1981 3 50.55(e) report.

(2) The County provides inadequate basis to conclude that this is a quality assurance problem that is relevant to Shoreham.

In fact, LILCO has confirmed that pump motors at Shoreham do meet applicable requirements. Kammeyer Affidavit at 10.

i Paragraph 7. LILCO objects to this contention. (1) It is untimely because it is based on a 1981 Part 21 report. (2)

LILCO uses different air check valves on its diesels and there-fore the concern is not relevant to Shoreham. Kammeyer Affida-vit at 10.

Paragraph 8. LILCO objects to this contention. (1) It is untimely because it is based on a 1980 $ 50.55(e) report.

(2) The County provides no basis to demonstrate that this con-dition is applicable to Shoreham. In fact, LILCO has inspected the internal baffling of the heat exchangers and did not find problems of the type noted in this contention. Kammeyer Affidavit at 10.

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Paragraph 9 LILCO objects to this contention because the County has failed to provide any basis to conclude that it is applicable to Shoreham. Moreover, thrust bearing clearance must be checked prior to operation and periodically. The  ;

thrust bearing checks for the Shoreham diesels have not shown any abnormal conditions. Kammeyer Affidavit at 10-11.

1 I

Paragraph 10. LILCO objects to this contention. (1) l It is untimely because it is based on a May 27, 1983 S 50.55(e) report. (2) The County has provided inadequate basis to con-

. I clude that this condition is a quality deficiency applicable to j l

Shoreham. In fact, the condition appears to refer to l switchgear coinponents which, at Shoreham, were not supplied by TDI. Kammeyer Affidavit at 11.

Paragraph 11. LILCO objects to this contention. (1)

It is untimely because it is based on a 1980 S 50.55(e) report.

(2) The County has provided inadequate basis to conclude that it is a quality deficiency applicable to Shoreham. In fact, pipe supports on the Shoreham diesels are not required to meet the ASME Section III Code. Kammeyer Affidavit at 11.

Paragraph 12 LILCO objects to this contention. The County has provided no basis for concluding that the governor problems reported in this Part 21 report are applicable to Shoreham.

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Paragraph 13. LILCO objects to this contention. (1)

It is untimely because it is based on a 1981 S 50.55(e) report.

(2) It is not applicable to Shoreham. Kammeyer Affidavit at 8.

Paragraph 14. LILCO objects to this contention. (1)

It is untimely because it relies upon a February 17, 1983 S 50.55(e) report. (2) The County provides no basis to conclude that this condition is applicable to Shoreham.

Paragraph 15. LILCO objects to this paragraph because it has nothing to do with TDI's quality assurance program.

This deficiency occurred because personnel at the Sho'reham site l had failed to torque certain bolts on the rocker arm assembly.

l This failure to torque the bolts resulted in operational loads causing damage to the subcover assembly. LILCO identified this matter and has taken appropriate corrective and preventive ac-tion. Kammeyer Affidavit at 11.

CONTENTION IV.C.

Paragraph 1. LILCO objects to this paragraph. It is designed to sweep into the Shoreham litigation the results of all of the NRC's inspections at TDI conducted over the last five years. The County has made no good faith effort to cull out those findings which may not be significant or which have no applicability to Shoreham. Indeed, a review of the audits

indicates that very few of the findings were considered viola-tions; most were deviations or non-conformances. The County's attempt to inject all of these NRC inspection reports into the Shoreham litigation reaffirms LILCO's view that the County's sole objective in filing these contentions is delay. It is im-portant to note that if the NRC had found matters of signifi-cance during these audits that were applicable to specific Delaval engines, the NRC would have insisted on the issuance of a Part 21 report. Moreover, the hAC inspection findings will be factored into the data base used in the DRQR program. Thus, I

although the matters raised in the NRC audits should not be I litigated in the Shoreham proceeding, they will be considered in the design and quality review of the Shoreham engines.

Paragraph 2 LILCO objects to this contention which references Board Notification 83-160 in support of the County's l allegations that there are quality deficiencies relating to TDI i diesels. To the extent that the County intends any additional litigation of this Board Notification beyond the individual items mentioned elsewhere in the County's contentions, LILCO objects because the contention is vague and unparticularized.

Moreover, as already noted, the question of the overall

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reliability of the Shoreham diesels will be addressed in the DROR program.

f Paragraph 3. LILCO objects to this contention. (1) It is untimely because it attempts to rely on old NRC I&E inspec-tien reports. In fact, the County attempts to revisit inspec-tion reports it cited when it moved to reopen the record in May, 1983. See, e.g., Memorandum and Order at 21, 22, 27 (June 22, 1983). (2) The paragraph is vague and unspecific. The County has made no' effort td discuss the particular details -in the inspection reports which it believes are relevant to this litigation. (3) To the extent the citation of these I&E re-ports is intended to provide support for its broader QA con-cerns, those concerns will be addressed in the Shoreham DRQR.

Paragraph 4. LILCO objects to this contention because it attempts to litigate matters that were raised in Stone &

Webster's audits and reaudits of Delaval in 1975 and 1976. The County has had these audits for almost five months and there-fore any effort to raise issues based on these audits is now untimely. Moreover, the County has made no attempt to identify specific items in these audits which indicate that the Shoreham diesels will not operate safely and reliably.

Paragraph 5. LILCO objects to admission of this con-tention because it is untimely. The County attempts to sweep into the litigation a report by an NRC consultant issued in July, 1983. In addition, many of the items listed in the e

report merely repeat matters contained in prior NRC I&E Re-ports. Moreover, the County has made no effort to identify with specificity which portions of the report it wants to liti-gate.

CONTENTION IV.D.

Paragraph 1. This issue will be litigated as part of the existing cylinder head contention.

Paragraph 2. LILCO objects to this contention because the County has provided no basis to support its conclusion that the replacement crankshafts were not manufactured in accordance with the requirements of Appendix B. To the contrary, Appendix B vendors such as TDI are permitted to procure components from qualified subvendors specifying the necessary quality standards and quality measures that should be applied by those subvendors. In the case of the Shoreham replacement crank-3 hafts, Krupp is a qualified manufacturer of crankshafts and was subjected to quality requirements specified in accordance "

with TDI's Appendix B program. Kammayer Affidavit at 11-12. L l

1 Paragraph 3 LlLCO objects to this paragraph because it is broad and unspecific. It appears to challenge the ade-quacy of all of the replacement components used for Shoreham.

l To the extent that the adequacy of a particular component is )

litigated, pertinent quality measures will be considered, if appropriate. LILCO also notes that additional surveillance ac-tivities have been con 6 acted for significant replacement compo-nents such as the crankshafts and pistons. Kammeyer Affidavit at 11-12.

CONTENTION IV.E.

LILCO objects to this contention. (1) It is untimely because the County has had LILCO's audits of Delaval for almost five months. (2) The contention is without adequate basis.. As information provided to the County reflects, LILCO's initial l

reviews of TDI's QA manual did cover the area of design con-trol. In addition, the DRQR is designed to assess the adequacy of Shoreham diesel generator design as it exists today. Be-cause the DRQR design review is independent of the TDI design control program, it is a more reliable assessment of the exisc-I ing design than would result from litigation of the design con-trol program in effect at TDI almost ten years ago.

ATTACHMENT B LILCO'S PROPOSAL FOR DIESEL GENERATOR ISSUES Pre-Fuel Load Issues

1. Crankshafts Whether there is adequate assurance that the replace-ment crankshafts for the Shoreham diesels will not fail due to torsional stresses imposed during anticipated normal and emer-gency conditions.

2. Pistons Whether there is adequate assurance that the replace-ment pistons for the Shoreham diesels will not fail due to cracking in the area of the crown to skirt connecting bolts.

3. Cylinder Heads See the Board's statement of the issues in Memorandum and Order at 4-5 (July 28, 1983).

4. Intermediate Push Rods Whether there is adequate assurance that the replace-ment intermediate push rods at Shoreham will not exhibit the push rod weld failures observed at the Getnd, Gulf plant.

S. Turbocharger Thrust Bearingsl/ I Whether there is adequate assurance that tne turbocharger thrust bearing and the turbocharger thrust bearing pre-lube system will perform their intended functions.

Long-Term Issues i

6. Vibration i

See the Board's statement of the issue in Memorandum 1

l and Order at 32-33 (June 22, 1983).

1 I 7. DRQR i

f The County will have the opportunity to review the DRQR l results and, if appropriate, raise additional issues.

} Schedule

. LILCO believes that it is appropriate to proceed with I

litigation of all of the pre-fuel load issues. With respect to jl j the crankshafts and cylinder heads, substantial information has i

S been available to the County for some time. With respect to i

the pistons, intermediate push rods and turbocharger thrust 1/ The appropriate wording of this issue may have to be re-4 viewed in light of the results of LILCO's investigation of the recent turbocharger failures.

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bearings, LILCO believes that reports on these matters will be available by March 1, though some may be available sooner.

LILCO will provide mora definitive information on February 22.

Following the conference of the parties on February 22, 1983, LILCO suggests the following schedule for litigation:

March 23 Completion of discovery April 6 File testimony April 13 Motions to strike due t

April 18 Responses to motions to strike and cross-examination plans due April 24 Commence hearings f

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LILCO, Fsbruary 7, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF JOHN C. KAMMEYER John C. Kammeyer, being duly sworn, deposes and states as follows:

My name is John C. Kammeyer. I am employed by the Stone & Webster Engineering Corporation as the Assistant Head of the Site Engineering Office at the Shoreham Nuclear Power Station. Among other things, my responsibilities include engi-neering matters relating to.the Shoreham diesel engines. Atta-ched is a copy of my resume.

The purpose of this affidavit is to provide information concerning various matters raised in support of LILCO's re-sponse to Suffolk County's proposed supplemental diesel genera-tor contentions. .

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Contention I.A.2. This Suffolk County contention claims that the greater weight of the replacement crankshafts will cause excessive wear on the main'bearinas. This statement is based on an inccerect assumption. The original Shoreham crankshaf ts.weigned 6230 kilograms whereas the replacement crankshafts weigh 6500 kilograms, an increase of less than 5%.

Given this small increase in weight, there is no basis to con-clude that there will be any significant increase in wear on the main bearing between the no. 4 and no. 5 cylinders. Also, LILCO has not observed any abnormal '1 ear on this bearing in the past that would indicate any unusual or excessive forces on the main bearings when the original crankshafts were installed.

Contention I.B.l. This contention claims that exhaust temperatures for the Shoreham diesels are "very high (approxi-mately 1100* F) and indicative of overrating." This is incor-rect. During operation of the Shoreham diesels at the raced load of 3500 KW, exhaust temperatures do not exceed 980* F.

Operation at the 2-hour rating of the diesels (3900 KW) results in exhaust temperatures which do not exceed approximately 1050' F. The manufacturer permits operation of the Shoreham diesels with exhaust temperatures up to 1100* F. Thus, the exhaust temperatures experienced during operation of the Shoreham die-sels are within the limits specified by the manufacturer.

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Contention II.A.6; Contention II.B.10. These conten-tions deal with electrical cables inctalled on the diesel gen-erstor for certain engine and panel circuits that were the sub-jec*. of a September 27, 1983 Part 21 report by TDI. In response to this report, LILCO replaced the affected cables with appropriately qualified cable. No further action is re-quired in response co this Part 21 report.

Contention II.A.7; Contention III.A.10. These conten- -

tions deal with the pitting found on the camshaft lobes for DG 101 during disassembly of the engines for replacement of the crankshafts. LILCO inspected the lobes on the camshafts for the othat two diesels and found no similar conditions. The af-fected lobes on the diesel generator 101 camshaft have been re-placed with new lobes. The pitting observed on the camshaft lobes had no effect on'the operation of DG 101. In addition, inspection of the camshaft is required as part of the routine periodic inspection program for the diesel engines. Thus, even if the camshaft lobes had not been reolaced, this inspection program would have identified any adverse changes in the condi-tion of the camshaft.

Contention II.A.9. The failures of the tubing refer-enced in this portion of.the contention were a result of inade-quate tube support. All of the tube runs on Shoreham's diesel l

engines have since been evaluated and modified, as appropriate, for proper support and there have been no recurrences of the type referenced in this paragraph of the proposed contention.

Contention II.A.ll. The improper clamping force re-ferred to in the letter referenced by the County means that the bolt was not properly torqued. The " bolt seizure" referenced in the letter would also be caused by the installation of the bolt. In either event, these relate to installation, not de-sign.

Contention II.A.12 This contention deals with the pitting observed on three of the cylinder liners during the in-spection of the diesel generators. These cylinder liners had been in use on the Shoreham diesels throughout the diesel gen-erator factory test runs and the site preoperational test pro-gram without any adverse impact on operation. LILCO elected to replace the affected cylinder liners even though they were ade-quate for service. It should be noted that replacement of cyl-inder liners is a normal maintenance item. These components are inspected periodically and replaced as necessary.

Contention II.A.13. This contention lists a number of product improvements incorporated into the Shoreham diesels. A number of the items mentioned in this list, e.g., items (f),

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(h), (i) and (j), are designed to improve maintenance on the diesels. One of the items, item (b), was in part a modifica-tion made to facilitate the removal of the Shotaham diesels from the diesel generator rooms in preparation for replacement of the crankshafts. Thus, the product improvements or modifi-cations mentioned in this County contention do not necessarily reflect deficiencies in the original TDI dasign.

Contenti~on II.B.2. The governor lube oil cooler assem-bly referred to in this County contention is positioned in a location on the Shoreham diesel generators different from that on the engine (s) covered by the referenced Part 21 report.

Thus, the problem noted is not applicable to Shoreham.

Contention II.B.6. This contention involves the use of non-Class IE power to operate certain control devices on the diesels at the Perry station. This concern is not applicable to Shoreham because Shoreham uses Class IE power for all safety related diesel generator control circuits. Moreover, the in-stallation of the power supplies to the diesel generator con--

trol circuits for Shoreham was not performed by TDI but was performed at the site by LILCO and its contractors.

Contention II.B.7. The concern listed in this conten-tion is not applicable to Shoreham. When LILCO became aware of

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the incident at Grand Gulf, LILCO checked the torque on all the i

crankcase cover bolts to ensure that they had been properly torqued. LILCO also assured that generator guards were in place to prevent any loose objects from entering the genera >r and causing a problem similar to that experienced at Grand Gulf.

Contention II.B.8. The fuel oil line arrangement for the V-16 engine at Grand Gulf is different from the fuel oil line arrangement on Shoreham's in-line engines. Also, the fuel oil supply line that failed at Grand Gulf is not the same as the fuel oil high pressure injection tubes that failed at Shoreham. The Grand Gulf fuel oil line failed because of high cycle fatigue due to inadequate support of the line. LILCO has inspected the fuel lines at Shoreham to ensure that they have adequate supports to prevent the Grand Gulf problem from occur-ring at Shoreham.

Contention II.B.9. The problem identified in'the con-tention is not applicable to Shoreham. Shoreham's pressure sensing line between the starting air storage tank and the starting air compressor is seismically supported.

Contention II.B ll. The link rod assembly mentioned in  ;

this contention is'only used in Delaval's "V " engines and thus J

is not applicable to Shoreham.

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Contention II.B.12. The concern raised in this conten-tion is not applicable to Shoreham. The governor flexible drive ccupling at Catawba used an isoprene material. The Shoreham ciesels have a neoprene flexible coupling that is not susceptible to the type of deterioration that occurred at Ca-tawba.

Contention II.B.15. LILCO has a different type of pneumatic logic than that used on the Grand Gulf engines and thus the concerns raised in MP&L's February 1, 1982 S 50.55(e) report are not applicable to Shoreham.

Contention III.A.4. This contention references a fail-ute at the Grand Gulf station which is allegedly similar to the conditions reported by LILCO in SNRC-892. As noted in response to Contention II.B.8 above, the fuel line failure at Grand Gulf was in a different line and that occurrence is therefore not applicable to Shoreham.

Contention III.A.8. FaAA determined that the cylinder head nuts which had not failed during torquing would be accept-able during operation. Nonetheless, LILCO inspected all cylin-der head nuts for visual indications. LILCO replaced all ex-isting nuts with new nuts on DG 101 and DG 103 whether or not indications were found. Because DG 102 had already been l

reassembled, only those nuts with indications on that engine (3 out of 64) were replaced. The remaining nuts were left in place in accordance with FaAA's recommendations.

Contention III.A.9. The condition referenced in this contention was discovered as part of the normal check-out and initial operation (C&IO) process for the Shorcham diesels. The l

condition was corrected and no other similar instances have been discovered.

Contention III.B.3; Contention IV.B.13. The valve l

springs referenced in this contention were deficient because \

the subvendor supplier had not shot peened the springs in ac- 1 l cordance with the specification. This Part 21 report was not I

i applicable to Shoreham because LILCO was not suppplied with valve springs from the defective batch. In addition, LILCO in- I spected all of its valve springs to insure that the springs on  !

the Shoreham engines had been shot peened and uere supplied by TDI in accordance with the applicable specifications.

Contention IV.B.l. Shoreham's diesel engine pipes are not required to meet ASME Section III. Pipe welds on the Shoreham diesels have been inspected and found to meet the ap-plicable requirements.

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Contention IV.B.2. The missing bolts identified in this contention are bolts that are used to prevent slippage be-tween the cam gear and its hub in order to maintain proper timing of the engine. LILCO discovered this condition during

the routine pre-startup inspection of the engines and then ver-

! ified the timing of the engine.and installed the bolts. In any event, if this condition had not been discovered and the cam i gears had slipped, the engines would have remained operable.

Contention IV.B.3. Upon investigation of the condition 1

referenced in this portion of the contention, LILCO determined 4 that it was caused by improper alignment of the engine governor drive. LILCO repaired the governor and assured that it was properly aligned.

Contention IV.B.4. The condition cited in this portion of the contention was discovered by LILCO during inspections of the diesel generator required as part of the routine pre-startup checkout of the diesels. The crankshaft thrust had been checked at the TDI shop in Oakland prior to factory op-eration and found to be acceptable. The condition was attributed to damage incurred during shipment to the site-by.

rail. Thus, this condition does not reflect QA deficiencies.

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, Contention IV.B.S. The Shoreham diesel generators do not have and are not required to have any battery racks in-stalled.

Contention IV.B.6. LILCO has verified that all elec-trical pump motors for the diesels comply with the requirements in the specification'and purchasing documents.

Contention IV.B.7; Contention II.B.14. Shoreham diesel generators do not have check valves manufactured by the William Powell Company which were the subject of the Part 21 report referenced in this contention.

Contention IV.B.8 LILCO has inspected the internal baffling of the diesel generator heat exchangers as part of the normal check-out and initial operation process and no problems of the type noted in this contention were found. In addition,

as part of the periodic maintenance requirements of the Shoreham engines, inspections are conducted on the heat ex-changers' internals.

Contention IV.B.9. The thrust bearing clearance on the Shoreham diesels was checked prior to initial operation of the diesels. It has also been checked periodically since that ini-f tial operation, and no abnormal conditions have baen noted.

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9 Contention IV.B.10. At Shoreham, the switchgear compo-nents that appear to be involved in this contention were not supplied by TDI. Thus, the condition referenced in the Gulf States May 27, 1983 S 50.55(e) report is not applicable to Shoreham.

. Contention IV.B.11. Pipe supports on the Shoreham die-sels are not required to meet the ASME Section III Code.

Contention IV.B.15. This contention hac nothing to do with Delaval's quality assurance program. The condition re-sulted from the failure to torque certain bolts on the rocker arm assembly during the recent reassembly of the diesels at Shoreham. The inadequate torquing resulted in operational loads causing damage to the subcover assemblies in question.

LILCO identified this problem during the operation of the die-sel generator and took corrective and preventive action as re-quired by its quality assurance program.

Contention IV.D.2. The Shoreham replacement crank-shafts were manufactured by Krupp, a German foundry and manufacturing company. Krupp is qualified to manufacture crankshafts for Delaval's diesels. These crankshafts were man-ufactured subject to quality requirements specified by Delaval.

In addition, during the fabrication of the replacement

crankshafts, LILCO required that additional surveillance activ-ities be conducted by LILCO and Delaval personnel.

Contention IV.D.3. In addition to the normal quality assurance activities conducted by TDI for replacement compo-nents used a't Shoreham, LILCO and its contractors performed ad-ditional inspections and witnessing of quality activities for these components.

John C. Kammeyer STATE OF NEW YORK ) m

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CITY / COUNTY OF ) -

Subscribed and sworn to before me this day of February, 1984.

My commission expires:

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PROFESSIONAL QUALIFICATIONS JOHN C. KAMMEYER Engineer - Power Division / Assistant Head,

Site Engineering Office STONE & WEBSTER ENGINEERING CORPORATION

Education ,

Ohio State University - Bachelor of Science, Mechanical Engi-neering 1979..

Appointments Engineer, Power Division - February, 1981 Career Development Engineer, Power Division - June, 1979 Shoreham Nuclear Power Station, Long Island Lighting Company, (Nov. 1979 to Present)

As ENGINEER (Aug. 1982 to Present) assigned to the Site.Engi-neering Office (SEO) in the capacity of Power Engineer and As-sistant Head-SEO, respcnsible to the Head-SEO for the Power Di-vision effort. Responsible for directing engineers and designers in the resolution of construction and testing prob-lems dealing with fluid systems and related components, such as piping, valves, mechanical equipment, and equipment erection.

In addition, in the absence of the Head-SEO, responsible for the operation of the Site Engineering Office.

As ENGINEER (May 1981 - July 1982), assigned to the Site Engi-neering Office, responsible for resolving various engineering related construction problems, principally with piping and me-

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chanical components, requiring an immediate solution to support the construction schedule. In addition, working directly with the client's start-up organization to resolve system operation deficiencies.

As ENGINEER and CAREER DEVELOPMENT ENGINEER (November 1979 -

April 1982) in the Nuclear Engineering Group, responsible for preparing' reactor plant flow diagrams,. specifications, and FSAR 1 sections. As a Career Development Engineer, spent four months at the Site Engineering' Office, responsibilities included main-

- tainability study of the 850 MWe power. plant.

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. I North Anna Power Station - Units 3 & 4, Virginia Electric and Power Company (June 1979 - November 1979)

As CAREER DEVELOPMENT ENGINEER, assigned to the Nuclear Engi-neering Group responsible for preparing reactor plant flow dia-grams, specifications and FSAR sections.

U.S. NAVY (September 1969 - July 1975)

USS James K. Polk, SSBN 645 (April 1972 - June 1975)

Responsibilities included reactor operator, reactor instrumen-tation maintenance, supervision of division training; honorable discharge with ETR-2(SS) rating, commendation from Commander Submarine Squadron Sixteen.

Professional Affiliations American Society of Mechanical Engineers - Associate Member'.

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