ML20076K099
| ML20076K099 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/06/1983 |
| From: | Earley A LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8307080194 | |
| Download: ML20076K099 (6) | |
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UNITED STATES OF AMERICA
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y Yh$h?lg, II' Before the Atomic Safety and Licensing 7 Board *, \\ ;~,
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
(Shoreham Nuclear Power Station,)
Unit 1)
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Diesel Generator Schedule Pursuant to the Board's June 22 Memorandum and Order admitting portions of the County's proposed contention concerning the emergency diesel generators, LILCO submits the following proposed schedule.
As directed by the Board, the parties discussed schedule matters but were unable to reach complete agreement.
Consequently, a joint filing was not feasible.
The Board's June 22 Memorandum and Order admitted two limited aspects of the County's proposed diesel generator contention: the long-term effects of vibration and cylinder head cracking.
The Board ruled that the former need not be resolved prior to full load while the latter must be resolved before Shoreham operates.
The order acknowledged the possibility, however, that the fuel load / low power testing l-3 8307080194 830706 PDR ADOCK 05000322 n
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. aspect of the cylinder head cracking issue might be resolved through agreement or summary disposition.
Shortly after the issuance of the Board '.s order, LILCO and the County excnanged letters and, on June 27, LILCO sent documents (by Federal Express) to the County which were pertinent to both the vibration and cylinder head cracking issue.
On July 30, LILCO made a presentation to NRC Region I personnel in King of Prussia, Pennsylvania describing the results of LILCO's Diesel Generator Operational Review Program.
The County attended this meeting which addressed, inter alia, the matters admitted by the Board for litigation.
Following the session at Region I, LILCO and County lawyers and consultants met informally for several hours to discuss matters relating to the admitted contentions, focusing principally on the cylinder head cracking issue.
At this meeting LILCO emphasized its desire to resolve the low power aspects of the cylinder head issue expeditiously; the County emphasized that its consultants needed time to review the materials provided by i
L'LCO.
The parties agreed to confer on Tuesday, July 5 to determine whether any agreement on the low power issue was possible.
On the fifth, however, the County's consultants were not in a position to reach any conclusions un the low power issue.
Ratner, the County proposed a schedule for additional informal discovery leading to a County decision on the
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V acceptability of LILCO's interim surveillance measures in late July.
Given the Board's expressed schedule for issuing a partial initial decision by the end of July, LILCO believes the County's proposal was contrary to the Board's expectation of expedited consideration.
Moreover, it was unreasonable in light of the information already provided to the County by affidavit, at the conference of the parties and in informal discovery.
Consequently, LILCO has decided to file a motion for summary disposition immediately.
The County has been informed of this decision and LILCO and the County reached partial agreement on the schedule for the resolution of the cylinder head cracking issue.
The agreed upon portion of the schedule follows:
July 7 - LILCO files motion for summary disposition of cylinder head cracking issue.
July 8 - SC provides-LILCO with informal request for additional documents and description of documents /information to be provided by Deloval for the County's review.
July 12 - LILCO provi' des documents to SC on objections to request.
July 13 - SC consultants visit Delaval plant to review documents /information.
July 18 - Complete informal discovery.
July 22 -Parties inform Board of settlement or Suffolk County and NRC Staff file answers to LILCO's motion.
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Agreement could not be reached on the schedule beyond the 22nd.
LILCO suggests that if settlement is}not possible, and, as a result of the motion for summary disposition, the Board resolves the low powcr issue in LILCO's favor, any remaining long-term issues should be litigated on the senedule suggested by Suffolk County.
If the Board does not find that the motion has resolved the fuel load and low power testing aspects of the cylinder head cracking issue, LILCO requests litigation on the following schedule:
August 1 - Parties files written testimony.
August 8 - Commence hearings.
With respect to the vibration issue, the parties have had preliminary discussions and intend to pursue the matter further on an informal basis.
Because this issue need not be resolved before fuel load it is unnecessary to set a schedule for litigation at this time.
LILCO and 'the County propose that t{.e parties submit a status report on the issue on July 29.
If
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resolution has not been reached by then, the parties shall s,ubmit a schedule for litigation with that status report.
5 Respectfully submitted, LONG ISLAND LIGHTING COMPANY D,
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ANTHONY F.fARTE?, JR/
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LILCO, July 6, 1983 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 Diesel 4
Generater Schedule were served this date upon.the following by first-class mail, postage prepaid, or by hand, as indicated by an asterisk:
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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. James H.
Carpenter
- Administrative Judge Eleanor L.
Frucci, Esq.*
l Atomic Safety and Licensing
' Attorney 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 i
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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 pighway 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 8th 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, Esq.
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 s<^1 1.
Antliony F. Egley,T.
Hunton & Willi.ams 707 East Main Street P.O.
Box 1535 Rict.mond, Virginia 23212 DATED:
July 6, 1983
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