ML20076B703

Agrees W/Util Assertion That Crankshaft Failure in Emergency Diesel Generator 102 Should Have No Impact on Emergency Planning Schedule.Plant Completion & Readiness for Fuel Load Delayed by Crankshaft Failure

ML20076B703
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/17/1983
From:	Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Kline J, Laurenson J, Shon F Atomic Safety and Licensing Board Panel
Shared Package
ML20076B705	List: ML20076B703
References
ISSUANCES-OL-3, NUDOCS 8308190457
Download: ML20076B703 (3)

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. 50 -39s OL-3 KIRKPATRICK. I.,0NWAWT, HrII, CHRISTOPHER 6c M..avN va A PAmTwmasury twcLeptwo A PaormeeroMAL COnMELATMN moo M srazzr, N. W. '83 AUG 18 All :31 '

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' = QC: q C n(7 : 1 TELEPHONE (808) 468 7000 i i IN FITTs3VROX CABLE: NTFMI '"**NN tarvaamf JORN00N & IITCEISON TEL n 440909 RIPE UI 1600 OLITER BC122INO WEITER'S DISSCT DIAL NUMBBS FIIT8BCROM.FENNSTLTANI& 36888 (4ta) 358-0500 (202) 452-7064 August 17, 1983 BY HAND James A. Laurenson, Chairman ,

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Yesterday LILCO sent to you, for your information, two LILCO reports concerning the recent crankshaft failure in Emergency Diesel Generator 102. Mr. Christman's letter which accompanied the reports asserted that the diesel development should have no impact on the emergency planning schedule to be set by this Board. The County agrees with that conclusion of Mr. Christman -- because the schedule must be fair from the standpoint of providing the County and other parties with an opportunity to prove its case -- but has the following additional observations.

First, we enclose copies of the reports filed yesterday by the NRC Staff and the County relating to the crankshaft failure. Second, while the details concerning the crankshaft failure are not yet known, and the full impact on completion of the plant and readiness for fuel load will likely not be known for weeks or months, one thing can be said with confi-dence: the plant's completion and readiness fo- Juel load clearly has been delayed significantly by the crankshaft failure. Thus, if the emergency planning schedule being considered by the Board was to any extent impacted by LILCO's 8308190457 830817 PDR ADOCK 05000322 G PDR

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KIREPATRICK, LOCKuART, Exx.t., CuRrsroPumR & Part.z.rPS i

James A. Laurenson Dr. Jerry R. Kline Frederick J. Shon Page Two August 17, 1983 previous prediction of readiness to lead fuel by early October 1983, the new events certainly eliminate the basis for any such impact.

In addition, Mr. Christman's letter of August.16 indicates that LILCO believes there is no need to adjust the emergency planning _ schedule previously proposed by LILCO to the Board.

We find this surprising in light of discovery development,s which have occurred since the prehearing conference of August 9.

LILCO's proposed discovery period was premised on LILCO's preference "that all the parties forego the taking of deposi-tions altogether." LILCO noted, however, that "if the inter-venors insist on taking depositions, LILCO will find it neces-sary to take a number of deposition's as well." (LILCO's Recommendations to the Board for Prehearing and Hearing Procedures, at 5-6, n.1) Under the LILCO proposed schedule, all depositions were to be completed by September 9. (pi. at 3)

We were informed yesterday by LILCO's counsel that LILCO now tentatively wishes to depose a total of 21 of the County's witnesses and other persons. No estimate of the duration of j the depositions wa's provided. Counsel for the parties intend to meet on August 18 to: (a) determine how and when to schedule the 21 depositions now proposed by LILCO and the depositions of the 27 Staff, FEMA and LILCO personnel whom the County indicated-on August 4 it wished to depose; and - (b) attempt to resolve discovery disputes.

As we noted both in Suffolk County's Response to ASLB Request for Parties' Views on Emergency Planning Matters -(at 11-15 and 18) and at the prehearing conference (Tr . 329), the discovery schedule proposed by the County assumed that only the

County would conduct discovery depositions. The schedule pro-posed by the County was very tight; even with its assumption that only the County would conduct depositions, it contemplated that a deposition would be taken on every business day but 5 from August 29 to October 21.

Accordingly, the County requests that in setting the.fina3 discovery schedule, the Board take into account the need to i adjust (a) LILCO's proposed schedule to allow for the fact that l

now LILCO as well as the County will pursue deposition discovery,

( and (b) the County's proposed schedule by' adding to the deposition

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EIREPATRICK, LOCKHART Bru, Cuarstoruza & Purures James A. Laurenson Dr. Jerry R. Kline Frederick J. Shon \,

Page Three g' August 17, 1983 i, A

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period in that schedule the additional time necessary to accommodate the 21 depositions which LILCO now proposes to conduct.

Sincerely, A

Kar'la J. Letsc g KJL:so Attachments cc: Service List i

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UNITED STATES OF AMERICA NUCLEA11 REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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'LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

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(Sho eham Nuclear Power Station, )

Unit 1) )

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SUFFOLK COUNTY FILING REGARDING SCHEDULE FOR DIESEL GENERATOR CONTENTION Suffolk County is in receipt of the "LILCO Report and Request for Temporary Deferral," dated August 15, 1983. Suffolk County concurs in LILCO's request and adds only the following:

(1) It is unclear at this time the precise nexus of the new crankshaft development to either the cylinder head cracking issues or to the vibration issue. The County understands that the failure occurred when Diesel 102 was being tested with the new heads which had been installed, raising at least a possibility that there is a connection between the failure and the new cylinder heads. Also, the LILCO report, as well as a New York Times article (copy attached), state that the failure involved or was accompanied by excessive vibration. This raises the possibility of a direct relationship to the vibration issue. Until a failure analysis is conducted and the cause (s) is(are) determined, no precise conclusions can be drawn. However, it certainly appears -

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possible that any testimony which now is filed might need to be changed in light of data which will become available in the future.

(2) In discussions with NRC Staff personnel, it appears clear that full resolution of the crankshaft problem will take considerable time. Apparently Diesel 102 will need to be physically removed from its present location to an outside location where necessary disassemble / inspection / repair can be performed. The County has been informed by its consultants and by Staff personnel that the entire process is likely to take from several weeks, at a minimum, to several months. In view of the foregoing delays which appear inevitable, a brief deferral of the schedule as proposed by LILCO (i.e., a conference call for late August to discuss future scheduling) until more facts are known seems appropriate. The County suggests that LILCO be required to file a detailed status report with the Board and parties several days prior to any scheduled conference call.

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Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway i Hauppauge, New York 11788 L '

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. . AMeWe-l' . M , .x.y */ in Herbert H. Brown -

Lawrence Coe Lanpher Alan Roy Dynner KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.

Washington, D.C. 20036 Attorneys for Suffolk County August 15, 1983

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Crack in a Generatormayveiay-Shoreham AcomPlant's Opening.

-New York Times _ .- ByJAMES BARRON * -

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p. 32 - -~ A diesel generator that would supply bee preparing testimony for the hear-power in the event of a breakdown at ing, and they said they wanted to -

8/15/83 the Shoreham nuclear power plant do. pone it because they would all be .

veloped a crack during a tast, and an withthebroken crankahaft." -

of5cial of the Federal Nuclear Regula. The only worse'problemin a genen-tory.Commluion said yesterday that tor,heindicated,wasif themaincylln *

. the problem codd delay the plant's derblockweretocomeapart. .

opening. .. Miss Hicionan said that 1.!!co had The crack occurred in a crankabatt called the company that manuf actured Friday night dunng a test of three die. the Woot-imig crankshaft - Transa-sel generators that are designed to sup. merica Delaval of Califor:da-but did ~

ply auxiliary power in case the reactor not know how soon a replacement could

• at the Suffolk County plant has to be be shipped tn Shoreham, which is about shut down in an emergency. The com. 50 miles from Manhattan on Iong Is-mission most certify that the diesel landSound. ,

units will work correctly before the Generator Shutdown Before Long Island I.lghdag Company, owner -In AprH the camm4==4cn Sned LDc:r of the 53.4 billion ant, can begin gen.

000 fw imm W k a cal h ,g,y, suna diesel da s east sali the dent involved the middle diesel unit, enmm(== ion of5cial, M Gm known as No.102. Itis the sama gener.

man.

• I charam this as a @ ator that was shut down entiter this an ekman, a Luco spokaaman year aftw cracks wem detected in its, saidshe did not know how soonthe gen. NThe problem on Friday was noticed erstor could be repaired or how the shortly after 5 P.M., Miss Bicaman, problem would affect LHco's timetable said. Operates in die Shoretista com for the plant. The utility had hoped to trol roorn #W "ezcassive vibm-

. put the reactor, which is more than 10 dans k die generatz, sine said, d vears behind schedule and 10 times N

. "ver o budget, into commercial opers. 3 found l "

Miss said Luce had post. Yd*",8*"d1""*,*,'go",*s'*haftN 3

t a ed or next week. She also said the utility would der N shutdown h mward *h ask the comm-on m delay a hearing and of a six-bour test of the 3,500-kilo-on the diesel units that was scheduled watt unit. It was being run to produce tobegintheweekof Aug.29.. 3,904 kilowatts, in an overload condi.

Miss Hickman said it was too soon don, a test that is W by *be com.

for LDco to know how serious the diesel mission.

fallure was. But Alan Dynner, a lawyer Suffolk of5cials, who oppcee the representing Suffolk County, said that, opening of the Shombam. plant, said.

when Lilco's lawyers caDod him on they believed the diesel incident would Saturday to discuss > --q =E the mean a significant delay, and added bearing, "they said a vwy, very seri- that the problem underilned their con-ous occurrence had happened." cerns about safety and worirmanship at "It's the secced-worst thing that can the plant. The county has refused to ap-l happen in a diesel generator," Mr. prove an emergency evacuation plan Dy:mer said. "They told me it was so for the area around the plant, without serious they were semiing their experts which the plant cannot go into opera-back from California, where they had tion.

Cuomo Signs Law Giving Aid l .

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )  !

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LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (0.L.) l (Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copics of Suffolk County Filing Regarding Schedule for Diesel Generator Contention have been served to the following this /8 day of August, 1983 by U.S.

mail, first class, except as otherwise noted.

Lawrence J. Brenner, Esq. Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro Atomic fafety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.

Dr. George A. Ferguson 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board School of Engineering **W. Taylor Reveley III, Esq.

Howard University Hunton & Williams 2300 6th. Street, N.W. P.O. Box 1535 Washington, D.C. 20059 707 East Main St.

Richmond, Virginia 23212 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatcry Commission Mr. Jay Dunkleberger Washington, D.C.. 20555 New York State Energy Office Agency Building 2 ,

Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road

.Mineola, New York 11501 l

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Mr. Brian McCaffrey Stephen B. Latham, Esq.

Long Island Lighting Company Twomey, Latham & Shea 175 East Old Country Road P.O. Box 398

, Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901 Marc W. Goldsmith Mr. Jeff Smith i Energy Research Group, Inc. Shoreham Nuclear Power Station l 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David J. Gilmartin, Esq. H. Lee Dennison Suffolk County Attorney Building H. Lee Dennison Building Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik, Esq.

I Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 Law 2 World Trade Center

- Docketing and Service Section New York, New York 10047 office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory

• Edwin J. Reis Commission Assistant .hief Hearing Counsel Washington, D.C. 20555 office of the Executive Legal Director U. S. Nuclear Regulatory Commission Jonathan D. Feinberg, Esq.

l Washington, D.C. 20555 Staff Counsel, New York State Public Service Comm.

Stuart Diamond 3 Rockefeller Plaza Environment / Energy Writer Albany, New York 12223 NEWSDAY Long Island, New York 11747

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• Daniel F. Brown, Esq. Stewart M. Glass, Esq.

Atomic Safety and Regional Counsel Licensing Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency Washington, D.C. 20555 26 Federal Plaza New York, New York 10278 James B. Dougherty, Esq.

3045 Porter Street, N.W.

Washington, D.C. 20008 Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: August 15 , 1983 1900 M Street, N.W., 8th Floot Washington, D.C. 20036

• By Hand

• • By Telecopy

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