ML20092N524
| ML20092N524 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/29/1984 |
| From: | Tarletz D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20092N518 | List: |
| References | |
| NUDOCS 8407030240 | |
| Download: ML20092N524 (6) | |
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1 at Shoreham are capable and reliable for fuel loading and low power testing (Id. at 139); or as to any of the four categories he was to study (Id. at 104).
Dennis Eley, in his deposition, preliminarily concluded that the crankshaft was overrated but needed additional data before finalizing that opinion.
Eley Deposition at 119 (Attachment 2).
He indicated no final oci aion on any individual components.
Id.
He was not prepared to state that shot peening was inadequate on replacement crankshafts.
Id. at 143, 146-49.
Aneesh Bakshi only broadly commented based upcn what he had heard, but had no opinion in component-by-component questioning.
Bakshi Deposition at 69-75 (Attachment 3).
This charade is hardly " meaningful participation."
Not only does the County's pleading fail because it is unsupported,Lthe-County's challenge of the Shoreham EDGs fails because it has no basis in fact.
Such dilatory tactics subvert the entire adjudicatory process.
They would be subject to sanctions in federal court litigation and should not be condoned in this proceeding.
'8407030240 840629 PDR ADOCK 05000322
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PDR J
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t F By its own admission, the County states that it has been unable to ascertain whether those cy]inder heads were manufactured after 1980 and, therefore, whether they are similar to the cylinder heads at Shoreham.
On its face, this issue fails to comply with the Board's requirement that a nexus be shown to Shoreham.
Furthermore, the additional QA/QC procedures LILCO employed to ensure installation of acceptable heads makes LILCO's situation dissimilar from others.
4 In summary, all of the cylinder heads at Shoreham have been replaced with heads manufactured after 1980.
The fire decks of a number of these heads have been inspected for casting defects, welding defects and thickness after approximately 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of' operation, including 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at f
full load.
No relevant indications or deviations were reported, and these heads are suitable for unlimited operation.
(Owners Group Reoort On Cylinder Heads).
Furthermore, LILCO has initiated a barring over procedure recommended by the NRC to detect leaks in the unlikely event a head were to leak.
The County has presented no specification to refute that the extraordinary and conservative measures to assure the reliability and safety of the heads have been cuccessful.
o
A - testing of EDG 103 is complete.
Testing of EDG 103 will not change the extensive design and quality analyses that have already.been performed on the engines.
The County has had more than enough time to amass the information it needs to start this litigation.
LILCO does not dispute that EDG 103 must successfully complete the pre-operational test program and post-testing inspections before an operating license may be issued.
There is, however, no reason to delay the start of these proceedings.
(b)
New cylinder block testing program is not defined.
Response
The cylinder block in EDG 103 has been 4
replaced.
EDG 103 will repeat the entire start-up test prcoram.
After the start-up program has been completed, the engine will be partially disassembled and inspected.
4.
Procedures for increased engine maintenance, inspection, and surveillance actr-ities, including crack indications monitoring relied upon by the Owners Group, have not yet been issued.
Response
See the response to Part III Section A, Paragraph 4(a) -_(h).
The County has known for months wl.st components were being evaluated by the Owners Group Program.
The. task
.. descriptions, test procedures, component tracking. list, and other information have been available for months.
The County p-i
6 i'
' t-records and operating histories from TDI at least two months e
ago.
Yet, conspicuously absent from the County's request is a showing of any special circumstances or particular information in the possession of the TDI owners which would, under the Board's Bench Order, permit the County-to obtain additional
- discovery from the.TDI owners.
The County simply recites that i
it needs more information in three areas and lists the owners involved for each area without-any-sort of specification or particularization as to how this information will add anything.
to the information already available.
4 i
What'the Filing does show is that.the majority of
]
instances involved relate to marine-applications of TDI I
diesels.
But the County's own experts, Aneesh Bakshi e
and Stanley Christensen, have stated in their depositions that the operating conditions.and the-stresses-r ope.ating upon marine diesels are much different from those-f.
operating in nuclear standby application.. See~Bakshi l-Deposition at 89 and 100.(. Attachment 3);'Christensen l'
Deposition at 78-79 (Attachment 15).
tj' Furthermore, the County's assertion that piston crown-l cracking is an area that should-be added~to its contentions and- _
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in which discovery should be' conducted ignores'the' Board's
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- Shoreham specific requirement.
There is'no evidence in this proceeding:that any piston crowns:in the Shoreham EDGs have I
cracked.- The'information the County "may" be, seeking in these-w
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LILCO, June 29, 1934 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that a copy of the corrections to LILCO's Response To Suffolk County's Filing Concerning Litigation Of Emergency Diesel Generator Contentions was served this date upon the following by first class-mail, postage prepaid:
Atomic Safety and Licensing Herbert H. Brown, Esq.
Appeal Board Panel Lawrence Coe Lanpher, Esq.
U.S. Nuclear Regulatory Alan R. Dynner, Esq.
Commission Kirkpatrick, Lockhart, Hill, Washington, D.C.
20555 Christopher & Phillips 8th Floor Atomic Safety and Licensing 1900 M Street, N.W.
Board Panel Washington, D.C.
20036 U.S. Nuclear Regulatory Commission Mr. Marc W. Goldsmith Washington, D.C. 20555 Energy Research Group 4001 Totten Pond Road Robert E.
Smith, Esq.
Waltham, Massachusetts 02154 Guggenheimer & Untermyer 80 Pine Street MHB Technical Associates New York, New York 10005 1723 hamilton Avenue Suite K Martin Bradley Ashare, Esq.
San Jose, California 95125 Attn: Patricia A. Dempsey, Esq.
County Attorney Mr. Jay Dunkleberger Suffolk County Department of Law New York State Energy Office Veterans Memorial Highway Agency Building 2 Hauppauge, New York 11787 Empire' State Plaza Albany, New York 12223 Bernard M. Bordenick, Esq.
David A. Repka, Esq.
Fabian G.
Palomino, Esq.
Richard J. Goddard, Esq.
Special Counsel to the U.S. Nuclear Regulatory Governor Commission Executive Chamber, Room 229 State Capitol Maryland National Bank Bldg..
Albany, New York 12224 7735 Old Georgetown Road Bethesda, Maryland 20814
. e
.s Stephen B. Latham, Esq.
Howard L. Blau Twomey, Latham & Shea 217 Newbridge Road 33 West Second' Street Hicksville, New York 11801
'P. O. Box 398 Riverhead, New York 11901 Jonathan D.
Feinberg, Esq.
New York State Ralph Shapiro, Esq.
Department of Public Service Cammer and Shapiro, P.C.
Three Empire State Plaza 9 East 40th Street Albany, New York 12223 New York, New York 10016 James Dougherty, Esq.
3045 Porter Street Washington, D.C.
20008 b&*~
Darla B.
Tarletz Hunton & Williams P.
O. Box 1535 Richmond, Virginia 23212 DATED:
June 29, 1984 4
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