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Category:AFFIDAVITS
MONTHYEARML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20073B7461991-04-17017 April 1991 Affidavit of EM Franz Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7211991-04-17017 April 1991 Affidavit of Jl Bateman Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7941991-04-17017 April 1991 Affidavit of Jr Stehn Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing Intervention as of Right.W/Certificate of Svc ML20073B7821991-04-17017 April 1991 Affidavit of J Scrandis Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7161991-04-17017 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc (Sese) Re Intervenors Status for Sese ML20073B7611991-04-17017 April 1991 Affidavit of SV Musolino Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073A6101991-04-0505 April 1991 Affidavit of Jl Bateman Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A4631991-04-0505 April 1991 Affidavit of Ag Prodell Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A6161991-04-0505 April 1991 Affidavit of AP Hull Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A5831991-04-0505 April 1991 Affidavit of E Franz Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5571991-04-0505 April 1991 Affidavit of Jr Stehn Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A6041991-04-0505 April 1991 Affidavit of SV Musolino Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5511991-04-0505 April 1991 Affidavit of J Scrandis Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5301991-04-0505 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* ML20067C5361991-02-0303 February 1991 Affidavit of Franz,E M.* Affidavit Re Mod to Facility License ML20067C6721991-02-0303 February 1991 Affidavit of Eena-Mai Franz.* Believes Confirmatory Order Constitutes Another Step in Decommissioning Process to Violate Rights Under NEPA & Represents Threat to Health & Safety ML20067D0671991-02-0202 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Plant License. W/Certificate of Svc ML20067C4911991-02-0101 February 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* Affidavit of Mm Todorovich Re Organizational Interest in Modifying License to Plant ML20067C5881991-02-0101 February 1991 Affidavit of J Scrandis.* Affidavit Re Mod of Plant License ML20067C6101991-02-0101 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Facility License.W/ Certificate of Svc ML20067C8651991-02-0101 February 1991 Affidavit of Ag Prodell.* Opposes Confirmatory Order Issued on 900329,prohibiting Licensee from Placing Fuel Into Reactor Vessel W/O Prior NRC Approval ML20067C4991991-02-0101 February 1991 Affidavit of Jl Bateman.* Affidavit Re Mod of Plant License ML20067C5741991-01-31031 January 1991 Affidavit of SV Musolino.* Affidavit Re Mod of Plant License ML20067C5631991-01-31031 January 1991 Affidavit of AP Hull.* Affidavit Re Mod of Plant License ML20091C6711990-03-30030 March 1990 Affidavit of WE Steiger.* Provides Info in Support of Util Request to Amend Facility Physical Security Plan. W/Certificate of Svc ML20247B8831989-09-0707 September 1989 Affidavit of WE Steiger in Support of Util Request for Exemption from Onsite Property Damage Insurance,Per 10CFR50.54(w) ML20206M9851988-11-22022 November 1988 Affidavit of LC Lanpher.* Affidavit Re Govts 881123 Motion to Stay 881121 Licensing Board Memorandum & Order Authorizing NRC to Make Necessary Findings on 25% Power Issues & to Issue 25% Power License to Util ML20206M9921988-11-22022 November 1988 Affidavit of Gc Minor in Support of Motion for Stay.* Supports Govts Motion to Stay ASLB 881121 Order Authorizing Issuance of 25% Power OL for Plant ML20206N0001988-11-0303 November 1988 Affidavit of Ej Gleason,Director of Planning,State of Ny Energy Ofc.* Provides Data on Whether Supply of Electric Power to Long Island Would Be Adversely Impacted If Plant Did Not Operate.W/Related Info & Certificate of Svc ML20205R5351988-11-0303 November 1988 Affidavit of CA Daverio in Support of Lilco Response to 1988 Exercise Contentions.* ML20205N5231988-10-31031 October 1988 Affidavit of Kj Letsche in Support of Motion to Disqualify Judges Gleason & Kline.* Certificate of Svc Encl ML20205D6451988-10-14014 October 1988 Affidavit of Am Madsen in Support of Lilco Request for Stay of ALAB-902.* Certificate of Svc Encl ML20151N5851988-07-23023 July 1988 Affidavit of Dp Dreikorn on Lilco Compliance W/Fema Guidance Memorandum MS-1.* Certificate of Svc Encl ML20151G6051988-07-18018 July 1988 Affidavit of Ja Weistmantle.* Discusses Assertion That Lilco Obtained Complete Copy of Suffolk County Emergency Operations Plan Outside of Formal Discovery Processes ML20196B3571988-06-23023 June 1988 Affidavit of Jn Christman.* Schedule of Dispositions & Certificate of Svc Encl ML20151T4791988-04-21021 April 1988 Affidavit of Gc Minor & Sc Sholly Re Validity of Analyses & Conclusions Ref in Youngling Affidavit.W/Certificate of Svc ML20149H7411988-02-11011 February 1988 Affidavit of RT Hogan Re Disposition of Hosp Evacuation Issue,Per Rev 9 to Util Offsite Emergency Plan.W/Certificate of Svc ML20196D7771988-02-10010 February 1988 Affidavits in Support of Govts Opposition to Lilco Summary Disposition Motions on Contentions 1-2 & 4-10.* Supporting Affidavits Include Mm Cuomo,Pg Halpin,Rc Roberts,Je Papile, Kj Letsche & Rj Zahnleuter ML20196H1111988-02-0909 February 1988 Affidavit of Pg Halpin Re Matters Alleged by Util in Lilco Motions for Summary Disposition of Contentions 1-2 & 4-10 Dtd 871218.Summaries & Quotations of Util Assertions, Resolution 111-1983 & Pf Cohalan Statement Encl ML20196H0841988-02-0808 February 1988 Affidavit of Mm Cuomo Re Util Radiological Emergency Response Plan.Reaffirms Statements Made in 870506 Affidavit & 860630 Statement.Statement Encl ML20149D8311988-02-0404 February 1988 Affidavit of DM Crocker Re Suffolk County First Set of Requests for Admissions Dtd 880125.* Certificate of Svc Encl.Related Correspondence ML20149F1281988-01-25025 January 1988 Affidavit of T Urbanik Re Lilco Motion for Summary Disposition of Contentions 1,2 & 9.* Certificate of Svc Encl ML20148D4041988-01-19019 January 1988 Affidavit of Fg Palomino.* Util Had Matl Role in Activities Before Federal Govt by Endeavoring to Persuade Govt to Intercede in Proceeding During 1984 & 1985.Certificate of Svc Encl ML20148D3541988-01-19019 January 1988 Affidavit of Fr Jones.* Lists Conduct Supporting Fact That Util Has Not Made Good Faith to Secure & Retain Participation of Suffolk County ML20148D2281988-01-19019 January 1988 Affidavit of Gj Blass.* Util Refusal to Pay Property Taxes During 1984 & First Half of 1985 Constituted Severe Injury to County.Related Info Encl ML20148D1541988-01-19019 January 1988 Affidavit of LC Lanpher.* Submits Related Info to Support Contention That Lilco Has Not Made Isolated Good Faith Effort to Secure & Retain Participation of Suffolk County ML20147D7301988-01-15015 January 1988 Affidavit of Ms Miller Re Proposed Offsite Emergency Plan. Certificate of Svc Encl ML20148D3101988-01-11011 January 1988 Affidavit of T Urbanik.* Assumptions,Speeds & Methodology Used in Hosp Evaluation Time Estimates in Rev 9 to Util Plan Correct.Estimates Suitable for Inclusion for Use in Making Protective Action Recommendations.W/Certificate of Svc 1993-09-14
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
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.s to Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
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1 (Shoreham Nuclear Power Station,
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Unit 1)
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AFFIDAVIT OF EDWARD J.
YOUNGLING Edward J. Youngling, being duly sworn, deposes and says as follows:
1.
My name is Edward J.
Youngling and I am employed 1
by the Long Island Lighting Company (LILCO) as Startup Manager for the Shoreham Nuclear. Power Station.
My professional quali-fications have been previously su'bmitted to the Board:
As Startup Manager, I am responsible for all preoperational test activities.
I also coordinate Checkout and Initial Operation (C&IO) testing and preoperational testing.
In this role I have J.
- i been-directly involved in the testing of Shoreham's diesel gen-erators and jn, resolving related issues that developed during testing.
Specifically, I ain familiar with the County's contention regarding Shoreham's diesel generators.
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i 2.
I testified previously in this proceeding as a member of the LILCO panel on the Quality Assurance / Quality Con-trol issues.
I have also submitted two previous affidavits to the Board regarding Shoreham's diesel generatfors dated May 16, 1983 and June 3,
- 1983, On June 10, 1983, I appeared before the Board to answer questions regarding Shoreham's diesel genera-tors.
3.
This affidavit addresses that portion of SC's con-tention on diesel generators that alleges the diesel generators may not start or operate as required unless and until the cyl-inder head cracking issue is resolved for the Shoreham diesels.
SeeMemorandumandOrderRulingonSuffokkCounty'sMotionto Admit New Contention (June 22, 1983) at 37.
This concern is based on LILCO's detection of a minor water leak in three of the 24 cylinder heads in the diesel generators.
To remedy this situation, LILCO replaced the three cylinder heads with improved, current production model cylinder heads.
In addi-tion, LILCO intends to replace all the remaining cylinder heads as soon as practicable consistent *with the schedule for preoperational testing and fuel load.
In the interim, prior to replacement of all cylinder heads, LILCO will implement a sur-veillance ("barring over") procedure to insure that leaks are
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promptly detected in the unlikely event any occur.
Any head exhibiting leakage would be promptly replaced with a new head of the current production model.
This affidavit demonstrates (1) that there is a reasonable assur-ance that there will be no further leaks in the remaining cylinder heads, (2) that LILCO's surveill,ance procedure
("barring ove-r") provides adequate assurance of reliable rapid start capability by insuring that leaks would be promptly detected in the unlikely event they do occur, and (3) that leakage of the type previously detected at Shoreham, if any were to occur and reraain undetected, would not affect the quick start capabflity or the safe and reli-able operation of the diesel generators,.nor would such leakage prevent the diesel genera-tors from carrying their full design electri-cal load.
4.
As noted in my May 16, 1983 affidavit, early in I
the preoperational testing process, three cylinder heads of the Shoreham diesel generators experienced cracks that resulted A
from manufacturing casting flaws.
In that affidavit, I stated that improved casting techniques and nondestructive testing and inspec' tion procedures have largely eliminated the possibility of casting flaws in current production models thereby greatly reducing the potential for cylinder head cracks.
I also stated that LILCO will replace all cylinder heads with those produced
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with improved casting and inspection techniques.
Qualified LILCO personnel have conducted an inspection and audit of the improved Delaval process which confirmed that improved casting and inspection techniques have been implemented at Delaval to ensure that casting imperfections of the type previously iden-tified in the three Shoreham cylinder. heads will not occur in the current productiob model heads.
The three cylinder heads that experienced cracks have been replaced with these improved, current production cylinder heads.
5.
Failure analyses conducted by the vendor, Transamerica Delaval Inc. (TDI), determined that the cracks were' caused by operating stresses from cylinder firing pres-TDI has informed LILCO that casting flaws exist only in sure.
a small percentage of cylinder heads identical to those origi-nally supplied with the Shoreham diesels-and that based on ex-perience, cylinder heads that develop leaks similar to those experienced at Shoreham do so prior to completing 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of operation.
Each of Shoreh'am's diesels now has over 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />
-of operation (DG 101 - 617 hours0.00714 days <br />0.171 hours <br />0.00102 weeks <br />2.347685e-4 months <br />,'DG 102 - 693 hours0.00802 days <br />0.193 hours <br />0.00115 weeks <br />2.636865e-4 months <br />, DG 103 -
809 hours0.00936 days <br />0.225 hours <br />0.00134 weeks <br />3.078245e-4 months <br /> as of June 24, 1983).
'Because the generators have passed the 600. hour threshold, there is a reasonable assurance that there will be no leakage on any of.the remaining originally supplied cylinder heads.
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Thefailureana[lysisalsodeterminedthatthe cracks were of such a nature that they would not have affected the performance of the diesel generators.
The cracks were self-relieving, nonpropagating, and of small'sizel_/ so that they had no impact on the mechanical strength of the head.
As noted in my May 16 affidavit, any water that would leak into
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the combustion chambers as a result of these cracks would be s
expelled via the exhaust system along with other combustion by-products.
Thus, despite the small leaks that occurred, the reliability of the cylinder heads during operation was not af-fected.
Additionally, there is no impact on the ability of the diesel generator or the individual cylinder head with a crack to carry its full load.
For example, in marine applications, engines with cracked cylinder heads are operated for weeks without any effect on the reliability or operation of the en-gines.
If In my May'16, 1983 affidavit, I reported that th'e largest of the leaks was at a rate of 9.25 gallons per hour.
This rate was during operation of the diesel and the water was expelled via the exhaust.
When the combustion chamber was inspected after shutdown, only a small amount of water-(approximately a cupful) was found in the combustion chamber.
This confirms (i) that the water had in fact been expelled through the exhaust-during operation and (ii) that the leakage rate after shutdown is very low and is no impediment to the rapid start capability of the diesel generator.
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7.
Even though LILCO and TDI believe that the number of operating hours on each engine makes it unlikely that any more cylinder heads will experience leaks, LILCO will institute a surveillance procedure ("barring over",) by which water leak-age will be promptly detected.
This procedure gives further assurance that should a leak occur, it will have no impact on the quick start capability of the diesel generators.
This sur-
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veillance or "barring over" requirement is contained in Shoreham's draft Station Procedure 27.307.02, " Emergency Diesel Generator Cylinder Leak Detection Test."
In accordance with this procedure, the plant operator, using the barring device, will mechanically turn the engine over several complete revolu-tions.
Water present in the cylinders will be forced out through the indicator cocks where it will be observed by the inspector.
Water will not be forced out the exhaust system and go undetected because all four valves for each cylinder close prior. to the piston reaching top dead center.
The inspection '
intervals specified in SP # 27.307.02 are four, eight.and twelve hours after the diesel generator is shut down.
This is in accordance with the vendor's r;ecommendation.
The "barring over" practice is a well-established one.in the.large diesel generator industry for exactly the same reasons it is being im-plemented'at Shoreham.
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The surveillance or "barring over" intervals specified in the procedure are appropriate in light of the na-ture of the small inaks and low leakage rates involved in these instances.
TDI's analysis of the three affected Shoreham cyl-1 inder heads indicates that these cylinder heads developed small cracks and leaks as a result of the action of high cylinder firing pressures on tihe rarely occurring casting flaws in the s
cylinder heads.
After shutdown, and as the diesel generator cools, the cracks, if any exist, close and leakage steps.
Thus, the first "barring over" is the four hours after shutdown because the temperature in the combustion chamber early in the four hour period following shutdown is sufficiently high that the characteristically small leakage will evaporate.
At four hours, however, leakage would begin to be detectable.
"Barring over" beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after shutdown is unnecessary because by this time the diesel generator has cooled to a steady state standby temperature and cracks, if any existed, would have closed and leakage ceased.
Four hour intervals for su,rveil-lance suxi "barring over" are appropriate because post-shutdown leaks of this nature'are characte,ristically of such a slow rate that more frequent "barring over" is not necessary.
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In the unlikely' event of any additional leaks at Shoreham, operating personnel, by observing the jacket water level instruments, will be able to detect water leakage during operation.
Leakage c curring after shutdown will be detected by the surveillance ("barring over") procedure.
If a leak oc-curs, the inspector is to notify the ifatch Engineer who, in turn, will declare the diesel generator inoperable.
The cylin-der head must then be replaced.
Once an engine is declared in-operable, the technical specifications dictate the course of action to be taken.2/
10.
In summary, given that Shoreham's diesel genera-tors have more than 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of operation, there is reasonable assurance, in light of the experience of Delaval with large numbers of identical cylinder heads, that there will not be any additional cracks or leaks in the remaining cylinder heads.
Moreover, LILCO's surveillance ("barring over") procedure pro-vides reasonable assurance of reliable rapid start capability by ensuring that leaks would be promptly detected even in the unlikely event that such additional leaks were to occur.
It is 2/
During low power testing, only two diesel generators are required to be operable under Shoreham Technical Specification 5 3.8.1.2.
This further lessens any concerns regarding cylin-der head cracking because if a leak develops, it will not hin-der the low power testing.
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also significant that leaks of the nature detected at Shoreham
- do not affect the safe and reliable operation of the diesel generators, including the quick start capability.
~
n Edward J.
Your 1
g' Subscribed and sworn to before me this Th day of July, 19 a.
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