ML20102A420

Submits Diesel Generator Info & Contentions 178-AA & 179-AA for Litigation,In Response to Past ASLB Order

ML20102A420
Person / Time
Site:	Harris
Issue date:	02/04/1985
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-463 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8502080366
Download: ML20102A420 (6)

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UNITED STATES OF AMERICA

• ggg NUCLEAR BEGULATORY COMMISSION CCFKEIED A

BEFORE THE AMMIC SAFETY AND LICENSING BOAgi FE8 -7 P1:09 Glenn O. Bright Dr. James H. Carpenter LTilCE e E LRt7;r' James L. Kelley, Chairman t:0;MEig EWf

. In the Matter of CAB 0 LINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit i _' ~) ) ASLBP No. 82-1568-01

) OL Diesel Generator Contentions and Information In response to past order of the Board, Wells Eddleman urovides.

the following information and new contentions. I have obtained the expert assistance of Dr. Robert N. Anderson, Professor of Materials Engineering at San Jose State University. (A cony of Dr. Anderson's overview of his qualifications from Shoreham case is attached; having i

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the flu prevented me from getting his Attachment 1 in hand, but his qualifications are well known to the NRC Staff and Anplicants and the Board can readily verify 'the n. Attachment 1 will follow when I' get- it. )

Dr. Anderson will review the test resalte fron Applicants' diesel generator functional testing and teardown / inspection,: assist me in preparing a-critique and cross-examination, and if necessary and feasible he will.be available.as a witness. Dr. -Anderson assisted

.in preparing the.following contentions.

L Diesel Generator Contentinns ,

178-AA*, CP&L has not established by appropriate operational r

• Extension of ~ time from l' February approved orally by counsel for

[- Staff and' Applicants, and'by the Board L

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$DRADOCK8502080366 PDR w 850204 O$

testing, and analysis of the results thereof (including results of . ,

inspections after teardown after testing, analysis of tested engine oil, and other anoropriate tests) that the TDI DSRV-16 diesel engines at .

I Shearon Harris have the capability to meet the loads they will be called

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on to meet in emergencies. Without emergency power available on a )

reliable basis, the health and safety of the public against serious .  ;

nuclear accidents resulting from loss of offsite power or other -

failures cannot be assured. (Harris diescis untested for operation, see Attachment 1 of CP&L letter to NDO NL9 84-52P,1/15/85, item 2, p.1; -

requirement of approcriate testing to assure the diesels can meet 1%

required loads is the exoert opinion of Dr. Robert N. Anderson.)

179-AA. CP&L's vendor (and other) inspection and QA is inadequate to assure that the TDI DSRV-16 diesels at Shearon Harris g have the requisite quality and operability characteristics to perform j their required functions. This is because variability of individual and tolerances -

l castings geffectively makes each DSRV-16 a custom unit. Any cuality -;

review or analysis based on other engines is therefore inadequate to assure the quality and operability of the Harris DSRV-16s. For use of information based on other engines, see TDI Uwner's Group submissions. -

The inadequacy of such analysis and the xxigan variability of the DSRV - j 16s are opinion of Dr. Robert N. Anderson.

<> <> <> q Ji Five factors. These contentions are timely because they comply ]

sa (under extension of time) with the Board's order. There are no other B ..

means whereby my interest in these matters will be represented , and no $2::

other parties are pursuing diesel generator contentions. These conten- gy tions are somewhat narrower than the original contentions 178 & 179; $

if they broaden the issues it is not to any great extent, and this g extent is obviously outweighed by the vital importance of having functional emergency power for the Harris plant. If there is doubt

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as to the reliability and function of the diesels (and Dr. Anderson shows such doubt because the diesels of this type are effectively custom units, i.e. the reliability of one unit does not assure the reliability of another; testing is required in any case to establish the reliability and operability of the emergency diesels and Applicants have not done that yet), then nositive findings on the issue are required for an operating license. The diesel issues were raised about 1 year ago, and are only one of nunerous safety issues, nost l of which have already been heard. -

The notential for delay on these issues is not great. Hearings on emergency planning are already scheduled in sunmer 1985, and fuel f --

load is not scheduled until March 1986. If these contentions were M

admitted by 1 March with the normal 65 days for discovery, and Applicants accomplish their testing on schedule, any summary disrosition notions could be filed in May and heard by the end of June, and hearings could be held by August. This is not a significant delay and should not impact fuel load which the Applicants have slipped.

If there is no record, there is not a sound record. With the assistance of Dr. Anderson, an expert who has particiented in a case ,

before the NRC involving another TDI diesel engine, I should be able to develop information discerning the nain Rnown flaws in CP&L's DS9V-16 diesel generators af ter they have been tested. To the extent that these flaws are significant, we can provide cromss examination and anpropriate information on those issues. At this noint no more detail can be advanced because the requisite information has not been developed by CP&L by testing of the diesels. Dr. Anderson's expertise is well known to the parties and Staff, or should be.

For the above reasons, contentions 178-AA and 179-AA should

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be admitted for litigation.

Wgils Eddleman 4 February 1985

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,SUFFOLK COUNTY, 7/31/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

_Before the Atomic Safety and Licensing Board

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! )

r In the Matter of )

)

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

)

(Shoreham Nuclear Power Plant, )

Unit 1). )

)

. )

l JOINT DIRECT TESTIMONY OF DR. ROBERT N.

ANDERSON, PROFESSOR STANLEY G. CHRISTENSEN, l G. DENNIS ELEY, ANEESH BAKSHI, DALE G. l

,: BRIDENBAUGH AND RICHARD B. HUBBARD REGARDING SUFFOLK 1 l

COUNTY'S EMERGENCY DIESEL GENERATOR CONTENTIONS j.

I INTRODUCTION l '.

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! Q. Dr. Anderson, please state your name, address and oc-l

=cupation.

l A. -My name is Robert N. Anderson, and my business address k- _ . . .

is Department of Materials Engineering, San Jose _ State Univer-p sity', San Jose, California. "I an'a Professor of Materials En-gineering at San Jose State University.

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'Q. .'Please. describe ~your.qualificati'ons'and experience

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which are relevant to the matters you. address in this testimo-

nr.

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. ~. . . - . - -. -. . -

4 A. I have a doctoral degree in metallurgy, a masters of science degree in chemical engineering and a bachelor of sci-ence degree in chemistry. My duties as Professor of Materials Engineering include teaching courses in casting and nuclear ma-n terials.- I am a licensed metallurgical engineer and nuclear engin~eer in the State of California, and I have qualified in

' court as an expert witness in metallurgy. I have actively con-l sulted in the field of failure analyses for 10 years. During that time, I have served as consultant to a wide range of L businesses, research facilities and local, State and Federal i agencies and commissions, including the California Public

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Utilities Commission, Brookhaven National Laboratories, IBM, Memorex, Lawrence Livermore Laboratory, the California State L Energy Resources and Development Commission, the Executive Of-L fice of the President'of the United States, Council on Environ-t-

mental Quality and Office of Science and Technology Policy, and c . the Office of Technology Assessment of the United States Con-

! gress. I have. published over 50 articles and I have had numer-L - ous patents issued to me in the field of materials science, L

L including fuel cycle patents and a nuclear reactor patent. I

-ami actively involved- in professional activities, holding mem -

bership in the'American Nuclear Society, the American Institute i ~of. Chemical Engineers, the American Chemical Society, the L

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American Society of Metals and the National Society for Professional Engineers, among others. I am also a member and past Ch' airman of the Northern California Section of the Ameri-can Institute of Metallurgical Engineers. A further statement of my professional qualifications is attached to this testimony

.as Attachment 1.

. Q. What, parts of thi's joint testimony have you espe-cially sponsored?

A. I am particularly sponsoring all of the testimony, pertaining to metallurgical science, including the properties of materials, crack initiation, propagation and arrest, details of the casting process followed by Transamerica Delaval, Inc.("TDI"), and analyses of the various methodologies applied by Failure Analysis Associates to matters of crack initiation and growth. I have not provided testimony regarding the func-tions or NRC regulatory requirements for emergency diesel gen-E erators.

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l 'Q. Professor Christensen e please state your name, address r

and occupation.

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A. My name is Stanley G. Christensen. I am a_ Professor

at the U.S. Merchant Marine

Academy, Kings Point, New York.

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