ML20076B961
| ML20076B961 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/17/1983 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8308220098 | |
| Download: ML20076B961 (38) | |
Text
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LILCO, Augus{17, 1983 DeCMETED USNMC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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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)-
)
4 LILCO'S MOTION FOR A PROTECTIVE ORDER IN RESPONSE TO SUFFOLK COUNTY'S RENEWAL OF ITS MOTION TO COMPEL On August 12, 1983, Suffolk County renewed its motion to compel discovery of certain documents that the County claims are relevant to the issue of cylinder head cracking.
In gener-al, LILCO objects to the request because:
(1) the requests are beyond the scope of the contention, (2) the requests are excessively broad espe-cially given the extensive discovery that the County has had to date on this issue, and (3) the requests are excessively burdensome given the ample opportunity the County has had to explore during depositions the availability of specific documenta-tion.
As this response reflects, LILCO objects to most of the County's requests, but will nonetheless produce some of the documents sought by SC.
A response +o each request is set out below.
LILCO's agreement to produce documents in response to 8308220098 830817 PDR ADOCK 05000322 O
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objectionable requests is not a waiver of its right to object to further document requests of a sitnilar nature or to object to testimony based on the documents produced.
A.
Quality Assurance Documents (Items 1, 2,
3 and 5)
Suffolk County's document requests in the area of qual-ity assurance reflect a desire on the part of the County to renew the already comprehensive quality assurance litigation in this proceeding.
The County attempts to legitimize its re-quests by claiming that it merely wants to ascertain the reliability of the cylinder heads on the Shoreham diesels by reviewing the quality assurance measures applied to them.
The transparency of the County's argument, however, is revealed by comparing the broad range of documents requested to the issues admitted by the Board!
The Board explicitly recognized that a general conten-tion concerning quality assurance matters at Delaval was inap-propriate at this stage of the proceeding.
In ruling on the admissibility of the diesel generator contention originally proposed by the County, the Board stated:
[W]e find that the first two unnumbered paragraphs comprise a broad, nonspecific preamble alleging generally the.t LILCO violates broad General Design Criteria applicable to diesel generators and broad Quality Assurance criteria i
('
This is partit
- 1y impermissible at this stage.
Board Memorandum and Order dated June 22, 1983, at 17.
And in discussing the portion of the County's contention dealing with preoperational testing, the Board said:
To the extent any part of paragraph 1 may he construed not as a new contention concerned with the reliability of the diesels, but rather as a request to re-open and continue the QA/QC litigation, it is rejected.
Id. at 24.
Finally, in succinctly stating the issues in this litigation following LILCO's unsuccessful motion for summary disposition, the Board made no mention of a general inquiry into quality assurance matters.
According to the Board, the issues are whether:
1.
Based on either analysis or operating experience, or both, the new Delaval production techniques have solved the problems which caused the cracking of the original type cylinder heads.
2.
The "barring-over" surveillance proce-dure for up to twelve hours after shut-down of the diesels will identify any cracks then existing in the cylinder heads (due to symptomatic water leak-age).
3.
The nature of the cracking problem and stresses exacerbating the cracks are such that no new cracks will be formed during cold shutdown of the diesels. -.
l I
i 4.
Any cracks in the cylinder heads and concomitant water leakage occurring dur-ing cold shutdown of the diesels which would not be detected by the barring-over procedure would suffi-ciently impair rapid start-up and operation of the diesels such that they would not perform their required func-tion.
5.
Any cracks in the cylinder heads occur-ring during operation of the diesels would prevent the diesels from per-forming their required function.
i Rather than focusing on the inspection techniques ap-I plied to the new cylinder heads, the County seeks to litigate whether the quality assurance program at Delaval meets the re-quirements of 10 CFR Part 50 Appendix B.
While an Appendix B QA program is in place at Delaval and may have some bearing on j
.the reliability of the cylinder heads, LILCO has not and does not intend to rely on the existence of such program to demon-strate that the new Shoreham cylinder heads are not likaly to leak.
Rather, LILCO and Delaval personnel have stated both in affidavits and depositions that they rely on particular produc-tion processes and inspection techniques to reach their conclu-sion that the new heads are unlikely to leak.
i 1
The distinction between relying on an overall QA pro-
. gram and relying upon specific techniques and inspections is i
consistent with the scope of the contention as envisioned by - -
the Board.
Drawing such a distinction is appropriate given the history of this proceeding.
During the litigation of the qual-ity assurance contentions, the County had ample opportunity to Inquire into whether LILCO and its vendors, including Delaval, had developed and implemented quality assurance programs that met the requirements of Appendix B.
In discovery on the QA is-sues, the County had access to LILCO and Stone & Webster au-dits, including audits relating to contractors and vendors.
During the months of QA hearings, the County conducted cross-examdnationconcerningtheQAprogramsofcontractorsand vendors.
- See, e.g.,
Tr. 11,074-76, 11,114-15 (Courter); Tr.
11,086-88 (Comstock-Jackson); Tr. 12,178-89 (Bergen-Patterson);
Tr. 12,147-59 (Stone & Webster PQC).
Thus, general inquiry into Delaval's QA program could have been pursued prior to the close of the record in this proceeding and should not be per-mitted now.
4 l
The prior opportunity to litigate compliance with Ap-pendix B does not, however, preclude all inquiry into quality assurance / quality control matters.
Those aspects of quality control narrowly focused on the inspection techniques upon i
which LILCO and Delaval rely in establishing tnat there is rea-sonable assurance that the new cylinder heads will not leak are relevant to the contention and appropriate subjects for i ;
discovery.
Indeed, the County has made numerous discovery requests related to these specific quality control measures ap-plied to the new diesel generator cylinder heads.
LILCO and D~elaval have responded to these requests providing copies of, among other things, the hydrostatic test procedure and magnetic particle test procedure for the new heads.1/
The County, how-ever, continues to press for documents well beyond those that have any direct bearing on whether the new cylinder heads will experience leaks similar to those encountered on the old Shoreham heads.
Therefore, the requests are excessively broad.
Notwithstanding LILCO's objection, in an effort to re-solve the issue LILCO and Delaval will provide the County with the following documents in response to Item 1 of Attachment A to the motion to compel:
1.
Delaval QA Manual 2.
Delaval Foundry QA Manual 3.
I.P. 100, I.P. 200, I.P. 400, and I.P. 600.
t 1/
Item 5 of the County's request, the liquid penetrant pro-cedure, deals with a specific test performed on the new heads.
LILCO does not object to this request and will provide a copy to the County.
If this document was previously requested, its non-production was merely an oversight.., - -
.. ~
It should be noted that during informal discovery on July 13-14, the County reviewed the Delaval QA Manual and I.P.
300, the In-process Inspection Manual.
At the County's re-quest, Delaval provided the County with a copy of I.P. 300.
In item 2, the County requests the documents that com-prised the Delaval Quality Assurance program in effect when the original Shoreham heads were produced.
LILCO objects to this overly broad request because it fails to focus on the quality control inspections specifically relied upon by LILCO and Delaval to ensure that the Shoreham cylinder heads are not likely to leak.
Moreover, this item deals with the old cylin-der heads which have been replaced with new cylinder heads.
Given the County's failure to focus on precise quality control measures and the questionable' relevance of the request, it would be unnecessarily burdensome to force Delaval to search its records to ascertain precisely what QA documents were in effect when the old heads were fabricated.
The Board should not impose such a burden given the extensive discovery the County has had with respect to the processes applied to the new cylinder heads.
As a result,- LILCO moves for a protective order precluding the discovery sought in item 2.
With respect to item 3 of Attachment A, LILCO objects to the County's request for records of all inspections, audits _ _ _.
or reaudits of Delaval's QA program.
First, as noted above, the County had access to audits conducted by LILCO during qual-ity assurance discovery.
Second, LILCO has already provided the County with a copy of the LILCO field audit (FA-1627) which focuses specifically on the quality control inspections relied upon by LILCO to establish that the new cylinder heads are un-likely to leak.
Suffolk County also deposed the author of this audit.
And third, the older audits requested by the County do not focus on the new cylinder heads and thus the request is overly broad and irrelevant to the question of whether the new heads will experience leaks similar to those found in the old heads.
This request reinforces LILCO's view that the County is attempting to broaden the scope of this contention despite the Board's rulings which keep it narrowly focused.
Accordingly, LILCO moves that the Board issue a protective order precluding production of those documents covered by item 3 of the County's motion to compel.
B.
Gating, Risers and Chills (Item 4)
Item 4 of the County's motion requests documents
" showing the gating, risers and chills for the 'old style' cyl-inder head molds and for the 'new style' head molds."
As the County has been told both informally and in depositions, there are no drawings which show the location of gates, risers and _.
chills for the old or new cylinder heads, nor are such drawings required by a regulation or industry practice.
As the deposi-tions reflect, it is industry practice to design molds from the d'esign drawings for the casting.
These design drawings for both the old and new heads have been made available to the County.
The County's request for these documents is particular-ly inappropriate given the number of discovery opportunities the County has had on this subject.
During informal discovery meetings conducted on July 13-14, the County's consultants were provided with lists of the changes made over the years to the production process for the cylinder heads.
These lists includ-ed changes to gating, risers and chills.
The County consul-tants were also given access t'o Delaval personnel familiar with these changes and were given a tour of the Delaval foundry where the actual molds in use could be observed.
Later, during the week of August 1, the County was provided with a consoli-dated list of over 60 changes identified in the lists previous-ly given to the County on July 13-14.
In addition, the County selected, and LILCO and Delaval made available for depositions, two witnesses knowledgeable in the Delaval casting process and the changes made to it over the years.
Pertinent parts of the depositions are Attachments 1 and 2 of this motion.
The i. -.
excerpts clearly indicate that the County had the opportunity to pursue these matters and chose to do so in a limited fashion.
The County's failure to avail itself of these exten-sive discovery opportunities justifies the issuance of a pro-tective order precluding further discovery on changes in the casting process. If, however, the Board concludes further dis-covery is warranted, Delaval will make available for inspection at its Oakland facility the actual molds used in the production of the old and new heads.
C.
Documentation Regarding Casting Defects (Item 6)
The documentation already supplied to Suffolk County by LILCO and Delaval comprises all of the documentation responsive to the County's request relating to casting defects.
In a telephone call subsequent to the filing of this motion, County counsel noted that the documentation did not appear to include
" warranty claims."
Delaval has informed LILCO that " warranty claims" were reviewed in response to prior requests and no re-sponsive documents were found.
With respect to the County's request for " documents which disclose the number of cylinder heads manufactured by Delaval between late 1978 and September 1980," counsel for LILCO informed counsel for SC that from June 1978 through the.-.
present, Delaval has produced approximately 2071 new cylinder heads.
In addition, Delaval will provide the daily foundry re-
.i ports for the period of July 1978 through September 1980.
These reports will list all heads cast during that time period.
Summary LILCO has or will provide documents responsive to items 1, 4, 5 and 6 of Attachment A to the County's motion to compel.
Some of these documents are produced over LILCO's objection and LILCO reserves the right to object to further similar discovery j
requests or to testimony concerning general QA matters.
LILCO asks that the Board issue a protective order with respect to 1
items 2, 3 and 5 of Attachment A precluding further discovery i
l on these matters.
I Respectfully submitted, LONG ISLAND LIGHTING COMPANY
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El$gs, III gf Anthony U Earley, A f Hunton & Williams Post' Office Box 1535 Richmond, Virginia 23212 DATED:
August 17, 1983 3 -
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ATTACHMENT 1
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3'
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
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5 6
7j In the Matter of 8i LONG ISLAND LIGHTING COMPANY No. 50-322 0.C.
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(SHOREHAM NUCLEAR POWER STATION, 9
UNIT 1.)
10 i'
Deposition of l
11 EDWARD S.
DOBRIC l
I 12 l
August 3, 1983 13 14 15 16 !
i 17 18 19 l1 20 21 22 23 24 25 26 27 Reported by:
ADELE I. NOLAN, CSR No. 1641, LESLIE TANIMURA-WONG, CSR No. 5796 28 WOLAN REPORTlWS SERYlCE INC.
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1 I S' D E X 1
2 Page Number 3
Examination by Mr. Miller 3,
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5 Examination by Mr. Earley.
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7 8
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'a Exhibit No.:
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1 Seven-page Foundry Practice Procedure document 16 49 17 18 19 20
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21 22,
- Exhibit bound separately.
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I NOkAN REPORTING SERVIEE INC.
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1 BE IT REMEMBERED that, pursuant to Notico of Taking 2
Deposition, and on Wednesday, the 3rd day of August, 1983, 3
commencing at the hour of 3:00 p.m. thereof, at the offices of l
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TRANSAMERICA DELAVAL, INC., ENGINE AND COMPRESSOR DIVISION, f
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550 85th Avenue, P. O. Box 2161, Oakland, California, before U
me, ADELE I. NOLAN, a Notary Public in and for the Ci'y and e
7 County of San Francisco, State of California, there personally 8'
appeared f
9' EDWARD S. DOBREC, t
called as a witness, who, having been duly sworn, was examined 10 -
I i
11 j and testified as hereinafter set forth.
---o0o---
I 12l 13 KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS, 14 1900 M Street, N.W.,
Washington, D. C.
20036, represented by 15 ALAN ROY DYNNER, Attorney at Law, and MICHAEL S. MILLER, 16l Attorney at Law, appeared as counsel on behalf of Suffolk "~
i 17 County.
18 HUNTON & WILLIAMS, 707 East Main Street, Richmond, 19 Virginia 23212, represented by T.
S. Ellis, III, Attorney at Law, and ANTHONY F. EARLEY, Attorney at Law, appeared as 20 I
21 counsel on behalf of Long Island Liyhting Company.
22 ORRICK, HERRINGTON & SUTCLIFFE, A Professional Corporation, 600 Montgomery Street, San Francisco, California 23 94111, represented by VICTORIA GRUVER, Attorney at Law, 25 appeared as counsel on behalf of Transamerica Delaval, Inc.
ALSO PRESENT:
Richard A. Pratt, Transamerica Delaval, 26 27 Inc., John C. Kammeyer, Assistant Head, Site Engineering 28 Office, Stone & Webster Engineering Corporation, MGkAM REFORTIWS SERYlCE INC.
1533 p.a.Saeet saa 8 aMoo CA 94109
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i 1iShorcham Nuclear Power Plant, Wading River, New York.
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EXAMINATION BY MR. MILLER 4
MR. MILLER:
Q.
Mr. Dobrec, my name is Mike Miller.
5 With me today is Alan Dynner.
We represent Suffolk 6
7 County in the licensing proceeding involving the Shoreham 8
Nuclear Power Plant, Suffolk County, New York.
9 The plant, as you know, I think, when built, is being 10 I constructed by Long Island Lighting Company.
11 We are here today to take your deposition for 12 discovery purposes in this proceeding.
13 ;
Q.
Would you please state your name and address, 14 l please?
15 i A.
Edward S. Dobrec.
16 Is the initial satisfactory?
17 Q.
Yes, sir.
18 And your address?
19 A.
Home address or business?
20 Q.
Business address is fine.
21 A.
550 85th Avenue, Oakland, California.
22 MR. MILLER:
Can we go off the record for a minute?
i 23 (Discussion off the record.]
24 MR. MILLER:
Back on the record.
Q.
Mr. Dobrec, can you please state your position at 25 20 Delaval?
27 A.,
Foundry Manager.
20 And for how long have you been Foundry Manager?
Q.
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THE WITNESS:
I wouldn't swear for sure if I saw this 2
one or not.
3, MR. MILLER:
G Mr. Dobrec, perhaps you could turn to i the next to the last pageoftheauditre[crt, which is 4
i 5
ldentified as FA dash 167, and this is the last two pages are
.6 r letter or a memorandum from Mr. Zeuthen to Mr. Milligan of 7,
LILCO.
8 You will note in the next to the last paragraph cf the 9
page, it sets forth a number of changes in foundry practice, 10 and they include, according to'Mr. Zeuthen, core design, the 11 location of risers, and chills, improved core supports, 12 alignment, sand mix, and core materials.
13 Do you see that reference, sir?
u A
[ Examining document.]
Yes, that's right.
15 C.
Wculd that be, tc your understanding, a complete 16 list of changes made with respect to the cylinder heads thhi l
17 have improved the manuf acturing casting processes of the i
e 18 cylinder heads?
19 '
MR. EARLEY:
I object to the question based on the l
l 20 ' document.
21 You didn't establish whether he was familiar with the 22 document.
23 He said he wasn't even sure whether he was familiar i
l 1
24 with the field audit.
l, 25 Why don't you ask him whether he was familiar with what 26 Mr. Zeuthen had to say there, and then go on.
27 I
MR. MILLER:
Mr. Earley, I'm merely asking the witness 28
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if he -- I have asked him -- I have referred him to certain i
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changes in foundry practico listed by Mr. Zeuthen, and I have 3
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l asked him if he agrees if that is a complete list of changes L
2 made with respect to the new cylinder heads that makes those i
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3 heads more reliable, a
f We nave already confirmed that the list is MR. EARLEY:
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5 i
the list of changes tha'. were made.
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7 MR. MILLER:
Let's try it a different way, Mr. Dobrec.
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8 0
With respect to risers --
o 9
A Yes.
-- have there been changes made in the risering of 10 0
11 the cylinder heads?
12 A Yes.
13 0
Which, in your opinion, improved the reliability of ti H
p 14 the cylinder heads?
N
!5 A
Yes.
that change' 16 C
Can ycu describe when that change -- what V
y 17 I was?
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p 18 A
In order to give the total change,"we would have to b
19 '. start right through the list.
20 0
Mr. Dobree -- and again we're going to try to save 21 l time here --
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4
- yes, p
23 0
-- what, other than going through this list which has been provided by Mr. Earley, could you just describe --
f 24 you have indicated there have been changes in the risering.
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Could you briefly describe what the change was?
increased.
The diameter of the riser has been changed, 27 A
28 The height has been increased.
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rico-o-therm is used on the conter riser, which is a highly 3
exothermic material that actually remelts a certain amount 2
of molten metal that is in a riser.
3 Exothermic sleeves have been added to keep the molten
.t 5l metal hot for a longer period of time to aid in the feeding 6
of the casting.
l 7-G Do you know generally when that change or these S
changes were made?
j 9
A.
They took place from '79 on through current.
t 50 0
Was the change in the risering made in response to 11 a particular problem or problems that had been experienced 12 or evidenced in the cylinder heads produced by Delaval?
13 A.
They were made to improve and cut down the rework of
'l the steel casting in the cleaning room.
15 O
So is it fair to say that the reason for the change 16 was for cast efficiency?
17 '
A.
Improve the quality of the product and cost.
18 '
They run hand in hand.
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19 0
Yes, sir.
20 Now with respect to gates, Mr. Dobrec, could you 21 5 briefly describe for me what changes had been made in the 22 ; gating of the cylinder heads that, in your opinon, would 23 improve the reliability of their currently produced cylinder 24 heads?
1 l
25,
A.
Yes.
The gating went from a joint gate, which then 26ldroppedtothebottomofariser,andcontactedfourrisers, 27 to cutting down to entering two risers to the final stage, 28 which is a crossover bottom core, which we bottom gate totally wel AW REPORTlWS SERYlCE INC.
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56 into the risors, which is one of the best foundry standard i
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practices that you can use, used in the industry quite 2
3 extensively.
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Am I correct, Mr. Dobrec, that the gates now cone t
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into the mold from the bottom of the mold?
5 1
i 6-A The gate is on the underside of the mold pattern.
7 it's still part of the mold.
6 0
Yes, sir.
i 9
A And it allows the molten metal to enter the casting 1C from the bottom.
11 0
Could you tell me approximately when the changes in 12 the gating were made by Delaval?
13 A
They are around '80,
'81 -- if the exact date is 14 in this list.
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t 15 0
Fine, sir.
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16 If you don't remember it, I received the list, and I f.
17 can find it.
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18 Was the change in the gating, Mr. Dobrec, made with r
19 respect, or in response to any particular problem or problems i
20 experienced by Delaval in the cylinder heads?
2I A The gating was made in response to -- and changes to 22 aid in the elimination of sand discontinuities.
23 It also, the change in gating, aids in solidification of l
24
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I the parts.
25 '
It allows the metal to enter the mold cavity so you can 26 have directional solidification for soundness and in areas 27 i where it is possible to eliminate hot tears.
O Mr. Dobrec, my question was:
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1 57 and so is it in rcsponse to any particular problem or problems, 3
that Delaval was experiencing problems in these areas correct 2,
such as sand discontinuities prior to the change made in -
3 4
gating?
We were experiencing normal foundry defects of sand 5i I
inclusion, hot tear, which is a foundry defect that transpires 6-7 to anyone that does cast complex steel castings.
Were these problems that had been experienced by 3
0 9
Delaval -- did they result in a higher than acceptable to 3
Delaval reject -- rework rate?
They resulted in higher rework than we would like.
11 A.
l The goal was to make them as reasonable and as low-cost 12 '
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13 quality as possible.
That is the job of a foundry man, i
14 4
So again, is it fair to say that, in part, the changes in gating were in response -- were in order to make more S
i efficient the cylinder heads produced by Delaval?
16 cost I said it was his -- in response to making a'better-17 l A.
quality part and reduce the cost of manufacture.
18 19 I O
Now would you agree, Mr. Dobrec, that there have been changes in the chills of the cylinder heads which have led 20 21 to a more reliable product of the cylindar heads?
Depending -- the placement of the chills, until they 22!
A.
23 ! are used at the most efficient point, will aid in making a l
24 I more reliable --
i I'm asking if Delaval has made changes in the 25 g
Yes.
26 l placement of the chills?
27 A.
Yes.
And approximately when were those changes made?
28 g
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Again, they cro listed in this list.
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I w uld have to go through it to give you approximate i
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dates.
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3 Mr. Dobrec, could you tell me G
Rather than do that, I'
2 if the changes made with respect to placement of chills was 5
oblems which had been l
.in response to a particular problem or pr 6
experienced by Delaval in the manufacture of its cylinder 7
i 8
heads?
Chill placed in the wrong area on a steel A Yes.
9 casting can enhance a hot tear.
10 feeding to cause shrinkage by cutting off It can affect 11 the feed metal during solidification.
12 And were these problems which Delaval was 13 0
experiencing which led to the decisien to change the placement
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15 of the chills?
r 16 A
Yes.
Delaval made the 17.
O Is it fair to say that, in part, i
g change in placement of chills also to lower cost of the 18 '.
b 19 i cylinder head?
you improve the quality, When you lower the cost, 20 A
because you do not need rework.
i 21 j
With respect to sand mix, Mr. Dobrec, have there 22l G
been changes in the sand mix?
23 I
24 A Yes.
if And approximately when were those changes made, U
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I 26 you recall?
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Those have transpired throughout the whole list o 27 A
I 28 changes.
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The major changes took place in the a'reas of the '79, 2
'80 era on.
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And were the changes with respect to sand misc in a
response to a particular problem or problems which had been 5
experienced by Delaval?
l 6
A They were made because the state of the art had
[
7, changed.
8 Equipment was available for new sand mixes that before 9
this time could not be used, u
10 They -- when the new equipment was made, shell sand 11 could be used, which takes special equipment.
12 '
These changes were all made also for the cost of 13 manufacture and quality.
11 O
Were the changes in sand mix made, in part, in 15 g
response to particular problems or problems which had been
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16, experienced in the manufacture of cylinder heads by Delaval?
i 17 A
Yes.
I 18!
MR. EARLEY:
Asked and answered.
I think that was the i
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19i last question he gave you the answer.
I 20 MR. MILLER:
G Now, Mr. Dobrec, with respect to what I fwillcallpatternequipmentimprovements,havetherebeen 21 22 changes made in pattern equipment improvements to the cylinder -
23 l
heads?
l 24 A
There has been new pattern equipment made for the 25. making of cylinder heads.
26 g would -- in saying that there has been new patterns, 27 new patterns made, did that include core supports?
20
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I support.
j.
in this foundry, It's a terminology that we don' t usa i
d.
and I have worked in several others, and I have not hear 2,
I 4
3 Would it include core desien?
O I,
4 A
Okay.
What was that second part?
5.
0 Core design.
6 What about the core design?
A 7.
j What is the question?
MR. EARLEY:
8 the The question is whether or not MR. MILLER:
g 9
improvements would include change to the core 10 pattern equipment i
11 design?
yes.
Core design and core equipment, A Yes.
12 would the pattern equipment improvements include the si 13 g
q core materials used?
H 14 Yes, because the type of boxes, the core equipnent I
15 A
made different core sands, could now be used.
f 16 i improvements include the would the pattern equipment P
0 17 g
18 alignment of the cores?
I 19 A
Yes.
Now, Mr. Dobrec, with respect to all these pattern g
r 20 ;
G improvements, were these the improvements made g
i 21 equipment approximately September of 1980?
l 22 l
23 A Yes.
I Were these improvements made in response to any l
24 4
by particular problem or problems that had been experienced n
25
)
Delaval in the manufacture of cylinder heads?
f 26 to the manufacture' number one, They were made problems,
)
27 A
poor equipment that was being --
28 of the head because of cost, i
1, I
wel, AW REPORTlWE SERVICE INC.
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,1 61 1
that was worn, that had been used for sovefal years.
1 2
l When the new equipment was made, it allowed the fcundry J
3 to ask engineering to give us some sections to allow better feeding, which would aid us in eliminating problems that 4
we had, 5j yes.
1 g
6 G
Were those changes in pattern equipment --
pattern k
7; equipment improvements at all in response to the goal of 8
lowering the cost?
9 A.
Lower the cost, and a better-quality part.
10 G
Mr. Dobrec, with respect to preheating of the heads 11 ! prior to welding valve seats --
12 A
And I'm not involved with the stelliting at a l '..
13 C
Where is that done, sir?
14 i
A.
That is done in the machine shop after machining.
H h
7 So you would have no knowledge regarding this fi 16 process of preheating?
g.
U!
A.
No.
IO 9
3 G
What about with regard to the stress relief, sir?
f l9 A.
The stress relief is done in the foundry, yes.
I 20
):
G Have there been changes in the stress relief process 21 } which, in your opinion, has led to more reliable cylinder heads?
ki 22 I A.
Yes.
23 g Approximately when were these changes made, sir?
A I believe they were around August of
'80.
A 25
.I If I'm not mistaken, '79 or
'80.
l' I'm not sure if it is.
I 27 4
That's fine, sir.
Okay.
28 Could you briefly describe what changes were made in the H
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I stross relief process?
1 2
A Okay.
The stress relief process, what it involved i
\\
is the casting has always been heat-treated.
3 It has always been stress relieved after repairs in the 4
l 5
foundry before it left the machine shop -- to the machine shop.
f l
6' After complete machining and hard facing for a period of 7! time, it was not stress relieved.
8 In around August, after the water test and final machining, 9
it was brought -- August of about '79 or '80 when stress 10 relieving began, that was the final operation.
11 It was returned to the foundry to be stress relieved as 12l the final operation.
13 g were the changes in the stress relieving in response
?,
to any particular problem or problems that had been experienced
'a I
15 by Delaval in manuf acturing the cylinder heads?
i 16 A There I believe we had some cracking of heads from f
I f
17; residual stresses, yes.
I 18 l:
(
O Now, Mr. Dobrec, with respect to p,ickling, is that a s
19fprocesswhichis--whichinvolvesthefoundry?
]
20 -
A No.
L 21 l
O Where is that process performed?
22 '
That process is done in the machine shop.
A p
L 23 It is, I believe they send them out.
i i
24 They do it in-house now -- or beginning.
,5 And if I understand your testimony from a little g
earlier, Mr. Dobrec, ultrasonic testing would not be performed W
26 i
27 F
in the foundry?
L 28 A Foundry, no.
L M9kAW REPORTlWS SERYlCE IWC.
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63
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I L
could you tell ma when the Delaval change Q.
Mr. Dobrec, j
from number one steel to number seven steel took place in the t*
2:
production of~ cylinder heads?
jd 3
and I think I can find it
[
A.
Let me look through here,
.2
}.
5 },in this list.
[Mr. P.att left the deposition room.]
6 6
7 THE WITNESS:
(Examining documents.]
Yes.
The number one to number seven was quite a ways back.
g.
Bi That's in the period of 19 -- late 1976.
9 Do you remember who suggested the change 10 MR. MILLER:
0 11 be made?
I would belive it would be Harold Helgerson, who 12!
A.
j 13 ' deals with the metal.
Do you know why the change was made from number one I4 0
15 steel to number seven steel?
16 '
A.
He describes it in number 4, in the list that you 17 have.
along with the hypercal, 18 l:
The higher manganese, 19 ! h-y-p-e-r-c-a-1, dioxidation practice minimized the deleterious 20 ! effects of sulfur.
2I Q.
Thank you, sir.
Mr. Dobrec, with respect to inspections of scrap 22 l
23 received by the foundry --
24 A.
Yes.
-- have you read and reviewed Mr. Avery's affidavit?
25 Q.
26 A.
Yes.
Then you are familiar, I assume, on page 6 of Mr.
27 G
"I was told by Ed Dobrec, 28 Avery's affidavit, he states, quote:
MekAW REPORYlWS SERVICE IWC.
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ATTACHMENT M i
g 1
UNITED STATES OF AMERICA I
2 NUCLEAR REGULATORY COMMISSION i
3i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
I 4i l
1
---o0o---
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1 7i 8
In the Matter of 9
LONG ISLAND LIGHTING COMPANY (SHOREHAM NUCLEAR POWER STATION, No. 50-322 0.C.
10 UNIT 1.)
11.
12 Deposition of g
HAROLD A. HELGERSON 13 August 4, 1983 C
16 '
17 l 18 i j
(
19l 20 21 !
22,
i 23 1
24
(
25 l
l 26 Reported by LESLIE TANIMURA-WONG, CSR No. 5796, ADELE I. NOLAN, CSR No. 1641 27
(,
28 i
i WOLAW REPORYlWS SERVICE INC.
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INDEX 1
Pace Number 2
g.
3 Examination by Mr. Miller.
6, 63 4
1 5
Examination by Mr. Earley.
51 0
6, 7
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18 19 20 21 22 l
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28 M9 HAM REPORTlWS SERVICE INC.
1533 p.ae Sweet Sam tea *cesco.CA W:9 fe'eoacaeeai5s928-8001
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f-l 2l jf BE IT REMEMBERED that, purcunnt to Notice of Taking l
2: Deposition ard on Thursday, the 4th day of August, 1983,-
r, 3
commencing at the hour of 9:10 a.m.
thereof, at the offices of
.g ; TRANSAMERICA DELAVAL, INC., ENGINE AND COMPRESSOR DIVISION, i
l 550 85th Avenue, P.
l O. Box 2161, Oakland, CA 94621, before me, j
5 g
.6 LESLIE TANIMURA-WONG, a Notary Public in and for the County 7'
of Contra Costa, State of California, there personally 8
appeared 9
l' HAROLD A.
HELGERSON, 10 called as a witness by Suffolk County, who, being by me first 11 duly sworn, was thereupon examined and testified as hereinafter 1
12 set forth.
13 -
---o0o---
14 KIRKPATRICK', LOCKHART, HILL, CHRISTOPHER & PHILLIPS, 15 1900 M Street, N. W., Washington, D. C. 20036, represented by
^.,
s 16 j MICHAEL S. MILLER,. Attorney at Law, appeared as counsel on I
17 behalf of Suffolk County.
I 18 HUNTON & WILLIAMS, 707 East Main Street, Richmond, 19 Virginia 23212, represented by ANTHONY F. EARLEY, Attorney at 20 ', Law, appeared as counsel on behalf of Long Island Lighting 21 i Company.
22 ORRICK, HERRINGTON & SUTCLIFFE, A Professional 23 Corporation, 600 Montgo'mery Street, San Francisco, California 24 94111, represented by VICTORIA GRUVER, Attorney at Law, appear'e'd ;
25 as counsel on behalf of Transamerica Delavaf, Inc.
26 Also present:
William B. Avery,' John C. Kammeyer, 27 Edward S. Dobrec, Richard A. Pratt.
28
---o0o---
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M9 HAM REPORTlWS SERVICE IWS.
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A.
I have read it, yen.
j
)
Q.
Do you have a copy with you, sir?
2 f-3 A.
Yes, sir.
It's right in front of me.
2 Q.
Would you look at page 9, paragraph 11, sir, of 5
Mr. Pratt's affidavit.
i I
f 6
Do you see there in the second line of paragraph
~1, l'.
7 !
it states, quote, "In the nine years since LILCO's engines 8
were manufactured, TDI has continued to develop and improve I:
9 the casting and manufacturing processes employed and 10,
produced in the four valve steel cylinder heads, like those 11 originally supplied with the Shoreham cylinders," closed 0
12 '
quotes.
13 Would you agree with that statement made by Mr. Pratt, 14 Mr. Helgerson?
)
- 5 A.
Very much so.
16 Q.
Are you familiar with the quote?
Are you familiar I
17 I with the casting and manufacturing processes which Mr. Pratt i
)
18 ;
says has improved the cylinder heads?
19 !
A.
Very much so.
Q.
Were you involved in those improvements to the 20 3
21 i
casting and manufacturing processes?
22 A.
Very much so.
23 i Q.
Could you tell me which of those casting processes I
'i
}
2#
you were involved with?
25 :
MR. EARLEY:
Well, could you focus on a particular 26 portion of Mr. Pratt's affidavit?
3 MR. MILLER:
Well, I don't believe, Mr. Earley, 28 Mr. Pratt's affidavit sets forth the changes in the casting WOLAW REPORTlWS SEltVltE INC.
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processes.
I j
Are you asking him for a listing of -
MR. EARLEY:
2 P
7 3;
changes?
I am asking him for a idsting of those MR. MILLER:
i 4
i changes in the casting processes which he was involved with.
1 5
If it would help, I will focus the question, j
2 6
Q.
i 7
Mr. Helgerson.
I think -- weren' t they given a list of 68 improve-8 A.
3 9
ments?
The County has been provided with the 10 MR. EARLEY:
I think it would be If we want to refer to the list, 11 list.
from memory.
3 12I a lot more efficient than asking him to do it l
13 THE WITNESS:
I have been involved with every one Il on the list.
Referring to the page entitled -- well, referring 4
15 Q.
~~
to the document which is five pages; the first page -is 1G IIl entitled:
Valve Steel Head 360-03-OF, which was made an attachment yesterday to Mr. Dobrec's depo'sition -- I think
)
l0 5
it's Exhibit 1 of Mr. Dobrec's deposition, Mr. Helgerson, it is your testimony you were involved in each and every 20 is that correct?
change that is specified on these five pages;
(
21 l
22 'I A.
Yes.
Let me try to focus you on some particular changes 23 Q.
g since this is a long list; okay?
24 25 ]
A.
Yes, it is, 26 '
With respect to changes in the risers for the l
Q.
27
-t cylinder heads --
28 i A.
Yes, sir.
l MOL AN REPORTlWS SERVltE INC.
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32 1
Q.
-- did you have involvement in that change?
2 A.
Yes, I did.
~
f 3
Q.
Can you tell me your involvement?
t s
4 A.
I am a foundry engineer.
One of my duties or i
5 responsibilities is to alter the riser or gating of a mold j
f 6
if it enhances the quality of the final product and that is 7
what these changes were for.
8 Q.
Could you tell me briefly, if possible, what 2
9 changes with respect to risering was adopted by Delaval?
10 A.
The riserings in some cases are made large to 11 give a larger reservoir of feed metal to the casting, which 3
12 also eliminates any possibility of microshrinkage or hot 13 tears in the casting.
l#
It is also made higher because a full reservoir 3
15 would make a bigger volume of molten metal; or there were,.,..,
16 riser sleeves that were added to the risers to save the metal I7;
-- molten metal, but to enhance the feeding characteristics B
IS !
of the risery, per se.
I l9 Q.
Now, Mr. Helgerson, with respect to chills, what 20 did Delaval do to improve the casting techniques with i
21 i
respect to chills?
22 l A.
A chill is used to place in a casting a 23 '
considerable distance away from a riser to enhance the 24 feeding distance the riser will feed; also, to eliminate any 25 possibility of a hot tear underneath the chill; and a chill j
26 can be either heavy sands, such as zircon, olivine, chromite 27 or it can be a metal; usually, iron or a steel.
28 i
In our case, we use exclusively steel.
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33 What.changsa Yes, sir, and my question would bes F
Q.
the casting
,j were made with respect to the chills to improve I
2 3j process?
Are you asking him to go through the MR. EARLEY:
h es?
Do you want him to generally summarize the c ang 4
list?
1 think because of the time, I will ask 5-MR. MILLER:
d with Mr. Helgerson to summarize what changes were ma e O
6 7
respect to the chills.
We add chills on the fire deck surface 8i THE WITNESS:
the riser C
9 originally, but then we remove those and increase l
i the chills 10 !.
and the feeding distance of the pad to eliminate J
11l i
rocess.
12 f to simplify the molding and the clean ng p d
It also gave a better fire deck surface and improve 8
We also took and put chills in the air 13,
it considerably.
i leaning 14 intake core to eliminate hot tears and excess ve c this
(
15 inside the intake core, which is the portion that
~
16 Shoreham hot tear was developed.
How do you know that is where the 17 MR. MILLER:
Q.
h cylinder
(
18l hot tear was developed with respect to the Shore am i
19 !
I 20[
head?
I said I hadn't I am not acquainted with it.
21 A.
I was told prior to this meeting that there was
(
i 22 reviewed it.
Mr. Pratt's a hot tear in the cylinder head, according to 23
[ indicating).
deposition here -- affidavitMr. Halgerson, I am goi 24
(
20 Q.
Yes, sir.
in the casting 1
the list of casting processes or changes 26
)(
27 processes at Delaval.
changes If you would please specify for me whether any 1
-t 28 MOLAW ltEPORTlWS SERVICE INC.
m a.se.c s s a-: ses :a w:s
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34 thnt you will diccuac cro changes not set forth on this 1
i 2l list that have been mentioned by Mr. Earley -- the list I
3 appended to Mr. Dobrec's deposition.
4 A.
No.
All the changes -- all the changes we have 5
made are listed here.
I 6
Q.
So, this list is an inclusive list?
7 A.
It is inclusive as of today.
8 Q.
With respect to gates, Mr. Helgerson, what changes 9
did Delaval adopt with respect to gating of the cylinder 10 i
heads?
.I 11 A.
Originally, the gating system -~- which I think l
12 Mr. Dobrec explained to you the reason for a gating system 13 i
so there's no use going through that again.
14 Q.
I think you have to go through it again.
15 l A.
All right, sorry.
16!
A gating system is to have the molten metal from the f
~
17 ladle go into the mold and into the various sections of the I
18 j
casting which have to be fed and to give a sound casting.
l i
19 It's called a runner system.
I*
20 I Portions of the runner system into the riser or 21 castin~g products are called gates -- in gates; therefore, 22 when we first started out with the gating system, as such, 23 we went into varicxs areas of the casting and into the risers 24 along the parting line between the cope and the drag.
There 25 is a possibility that occasionally, we pick up loose sand l
26 from this, because the metal flowing in these channels are
~
27 channels that are usually rectangular or square for convenience '
28 I
of molding.
I I
NGLAN REPORTINS SERYlCE INC.
- 533 Piee S eet Saa 8 amcisco CA ir09
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35
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Subacqu:;ntly, now, wn chtngad that and wa use as a 1j l
core, a cross-gate at the bottom of our two big outside risers. i 2
We pour directly down into that and go across the gate so all 3
the metal coming up -- the initial metal coming up 4
immediately goes into the bottom of the casting and does noX 5
3 6
' fall along any molding sand areas.
l So, that eliminates any possibility of loose sand 7
That was one coming from the gating system into the casting.
8 3
9 of the major changes we made.
Are there any other changes with respect to 10 Q.
gating, Mr. Helgerson, that you can recall at this time?
l 11 Well, originally we had gates that go into two of 3
12 A.
13 I the risers on the exhaust end.
I removed those because they 3
1 14 i didn't help the situation.
So, I had them go exclusively into the outside risers, O
15 8
which is on each side of the casting where they go now with"
16
?
That was the major change in the gating i
I7 a different system.
I i
18 system.
let me see if Q.
Mr. Helgerson, with respect to --
I can group some of this together -- with respect to pattern 20 equipment changes, are you familiar with changes which have j
g 21 been made by Delaval in pattern equipment changes?
22 23 I was responsible for it.
A.
Would those pattern equipment changes include 24
-(
Q.
25 core supports?
j l
26 A.
Some; a little.
Some, yes.
i Would it include alignment of the core supports?
27
.c Q.
28 A.
Oh, yes.
MGl.AM REPORTlWS SERVICE INC.
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36 Would it include thm : ora materials?
Q.
1 l
A.
Yes.
l 2
Q.
And the core design?
1 I
3 You j
Design is dictated by the blueprint.
A.
No.
4 can't change that.
I
-5 Let's take core supports, the core materials on the f
6 Q.
Is it fair to group those together as pattern 7
alignment.
8i equipment changes?
A.
Not core sand; just the supports and the I
9l C
i 10 i equipment.
I 11 Q.
Core supports --
l Core prints -- core supports, as you call it is lO 12 A.
13 core prints.
We call it in the foundry industry:
core prints.
14 Q.
Core prints; alignment of the cores --
-- caused by the core prints.
8 15 A.
16 !
Q.
And core materials?
That has nothing to do with the equipment.
17 A.
1 l
Maybe we can't group these together, then.
C 18 Q.
Okay.
You can in one respect for a simple reason.
19 A.
When we upgraded our equipment to get a better product, we 20 went from cores that were made in oil or no-bake sand to 2I I
shell sand, which eliminated any possibility of loose sand 22 I
in the mold and made a much better finish and a higher 23 24
\\
g quality casting.
It eliminated any possibility of loose sand in l
25 Q.
4 26 the mold?
' (*
A.
Right.
From Mr. Pratt's affidavit and other discussions, 28 Q.
MGkAM REPORTIWS SERVICE IWS.
533 8,ne Se eet Sa* 8+a c ses CA 94139 te ec one.415. W8 9X' k
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LILCO, August 17, 1983 2
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 copies of LILCO'S MOTION TOR A i
PROTECTIVE ORDER IN RESPONSE TO SUFFOLK COUNTY'S RENEWAL OF ITS MOTION TO COMPEL were served this date upon the following by first-class mail, postage prepaid, except by Federal Express, as indicated by an asterisk.
Lawrence Brenner, Esq.*
Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris
- Commission Administrative Judge Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Dr. George A. Ferguson*
Administrative Judge Daniel F. Brown, Esq.
Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing School of Engineering Board Panel Howard University U.S. Nuclear Regulatory.
2300 6th Street, N.W.
Commission Washington, D.C.
20059 Washington, D.C.
20555
- - - ~ - -
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,-----,w-
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,-.n-----..-my,-,,wn,
Bernard M. Bordenick, Esq.*
David J. Gilmartin, Esq.
David A.
Repka, Esq.
Attn:
Patricia A.
Dempsey, Esq.
U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington,.D.C.
20555 Veterans Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq.*
Stephen B. Latham, Esq.
Lawrence Coe Lanpher, Esq.
Twomey, Latham & Shea Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick, Lockhart, Hill, P.
O. Box 398 Christopher & Phillips Riverhead, New York 11901
.Sth Floor 1900 M Street, N.W.
Ralph Shapiro, Esq.
Washington, D.C.
20036 Cammer and Shapiro, P.C.
9 East 40th Street Mr. Marc W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, E3q.
Waltham, Massachusetts 02154 3045 Porter Street Washington, D.C.
20008 MHB Technical Associates 1723 Hamilton Avenue Howard L.
Blau Suite K 217 Newbridge Road San Jose, California 95125 Hicksville, New York 11801 Mr. Jay Dunkleberger Jonathan D.
Feinberg, Esq.
'New York State Energy Office New York State Agency Building 2 Department of Public Service Empire State Plaza Three Empire State Plaza Albany, New York 12223 Albany, New York 12223 k
' ).',.
l L' T/
..>-e,1
~
l Daniel O. Flanagan/
i Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
August 17, 1983 I
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