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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
[Table view] |
Text
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COCKETED UERC ATTACHMENT 1 UNITED STATES OF AMERICA
'N FB -5 P2 57 NUCLEAR REGULATORY COMMISSION
~
i Before the Atomic Safety and Licensing Board i
i
)
i In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
2 AFFIDAVIT OF STANLEY G. CHRISTENSEN Stanley G. Christensen, duly sworn, deposes and says as fol-lows:
1.
My name is Stanley G. Chrintensen.
I am a professor of marine engineering at the United States Merchant Marine Academy, Kings Point, New York.
I am currently one of the expert consul-tants for Suffolk County, New York.
My principal area of expertise is diesel engines,mphinawhich I have been involved for i
i i
over forty years.
My experience includes serving as chief engineer in charge of diesel engines in marine applications, and teaching a variety of courses on the design, manufacture, opera-l tion and repair of diesel engines and their components.
I am the i
author of numerous publications concerning diesel engines, including Lamb's Questiuns & Answers on the Marine Diesel Engine, I
a standard reference bouk.
My professional qualifications are set i
forth in more detail in Exhibit A to this Affidavit.
I have been B402070264 840206 PDR ADOCK 05000322 G
PDR
,Qgg,
1 g.
providing services to Suffolk County concerning the emergency diesel-generators ("EDGs") at the Shoreham plant since June 1983.
2.
The purpose of this Affidavit is to explain my technical 5
judgments regarding Suffolk County's proposed supplemental EDG contention I.
In reaching these conclusions I have reviewed and analyzed all of the reports and memoranda issued by Failure
-Analysis Associates concerning EDG parts and components which were made available to Suffolk County, as well as reports by the NRC I
Staff, documents concerning the EDGs furnished to the County by i
LILCO, and documents received by the County from owners and I
operators of other diesel engines manufactured by Transamerica Delaval, Inc. ("Delaval").
I have also visually inspected and taken measurements of certain parts and components of disassembled j
L EDGs, and I have visited Delaval's facility in Oakland, Cali-fornia, inspected the drawing of the Delaval cylinder head, and 1
i held discussions with Delaval personnel regarding the cylinder heads.
Finally, I have consulted various articles and texts as 4
appropriate.
j 3.
I have concluded that at 4890 horsepower and 3,500 kW, i
i each EDG at Shoreham is over-rated and undersized to meet the l
operating requirements of FSAR Section 8.3.1.1.5 for continuous i
operation (8,760 hrs.) at 3,500 kW and overload operation for 2 i
l hours in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period at 3,900 kW without reducing the 1
l maintenance interval established for the continuous rating.
4.
Each EDG is a Delaval model R-48 diesel engine.
The Delaval R series diesel engine was developed in the mid-1950's, i
i with an initial rating of approximately 250 horsepower per cyl-l 6
i
)
Y
inder.
The horsepower of the R series engines was increased to 611 horsepower per cylinder in the EDGs at Shoreham without any fundamental redesign of the engine.
Instead, changes were made in the design of particular components.
For example, in the late 1960's Delaval introduced the R-4 model (the same model as the
-Shoreham EDGs) with the current cylinder head design that in -
/?
creased the flow of air through the engine; by this change coupled O
with an increase in operating speed, engine horsepower was boosted without a major overall engine design change.
5.
A diesel engine is a complex piece of machinery whose parts are in dynamic inter-relationship.
Thus, a change in the design of a major component, such as a cylinder head, a crank-j shaft, or a piston, is likely to effect other engine components and, indeed, the performance of the entire engine.
In my judg-ment, the piecemeal changes made in the design of particular
}
components of the Delaval engine and other steps taken to more i
i than double the horsepower rating of the R series engine have i
resulted in an EDG which is over-rated and undersized.
For that reason, numerous parts of the Shoreham EDGs were found on dis-assembly to be damaged, and it is likely that additional damage will occur to parts and components with EDG operation at 3,500 kW or higher power.
My conclusions are supported by the factors dis-cussed below.
6.
I have concluded that the original crankshafts with the 11" pin cracked principally because they were undersized and poorly designed, although my reasons for this conclusion are 4
somewhat different from those of Failure Analysis Associates 1
("FaAA").
The standards for crankshaft design in large diesel engines (like the EDGs) used throughout the world by international insurance companies are those of the American Bureau of Shipping, Det Norske Veritas, and Lloyd's Register of Shipping.
These standards are more realistic than the voluntary standards of the Diesel Engine Manufacturers Association, an organization composed of six domestic engine manufacturers (including Delaval), whose standards are not approved by the American National Standards Institute or any recognized international standards organization.
FaAA failed to judge the adequacy of the original or of the re-placed crankshafts (with 12" pins) against the internationally 4
recognized standards for crankshaft design.
7.
From measurements of the replacement crankshafts and other data concerning their specifications, I have performed the necessary analysis to determine the adequacy of the replacement i
crankshafts under the applicable standards of Lloyd's Register of Shipping.
My analysis shows that the replacement crankshafts are inadequate for operation at overload power (10% above 3,500 kW) for periods more than 15 minutes.
Beyond that period the crank-shafts can be expected to develop one or more nucleation sites.
I While not necessarily visibly evident in the earlier stages of overload, such sites would later cause crankshaft deterioration and possibly failure.
I 8.
My analysis also establishes that even at normal loads up to 3,500 kW, the replacement crankshafts are only of marginal j
l design, with little capacity to safely handle additional potential l
stresses caused by such factors as unevenness in cylinder firing 9
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pressures, or failures of other components such as bearings, cyl-inder heads, or jacket water pumps.
Accordingly, one cannot have confidence in the reliability of the replacement crankshafts even when not operating at overload power.
9.
The greater weight of the replacement c::ankshafts and the consequent increase in the whirl created by internal unbal-anced centrifugal forces acting conjointly on the center main bearing will cause excessive wear on the main bearing between the number 4 and number 5 cylinder.
In addition, the effect will loosen the main bearing and cause ntisalignment of the crankshaf t, which could lead to crankshaft failure.
While the effect of in-creased crankshaft whirl may be somewhat ameliorated by the. fact that Delaval has reduced the weight of the replacement connecting rods, that design change might weaken 'ihe rods and cause problems in other bearing locations.
10.
The cracking of 23 of the 24 pistons in the three EDGs evidences that the pistons were of inadequate design to withstand firing pressures to which they were subjected in the over-rated EDGs, even after a relatively low number of operating hours.
This is another indication of the lack of design integration as the series 4 engines were uprated in horsepower.
Although I have not yet been able to examine a drawing of the replacement "AE" model Delaval pistons, I have analyzed information regarding their di-mensions and design.
My analysis leads to the conclusion that the model "AE" pistons are also of inadequate design to withstand operating conditions.
The ratio of the height of the piston skirt relative to the diameter of the cylinder bore (referred to as the
sliding length bore ratio) is too low This indicates that the bearing pressure of the sliding part of the piston skirt will be
' relatively high, causing overheating which can lead to increased wear on piston rings and to piston skirt cracking.
The fastening studs for holding the piston crown to the skirt appear to be in-adequate.
The tin plate surface of the skirt, while providing some benefit by preventing scuffing of the skirt, allows dirt to collact and thereby reduces piston clearance, which leads to over-heating and scoring the cylinder walls.
The position of the piston pin relative to the piston skirt is undesirably high, pre-sumably to accommodate a longer connecting rod.
This increases the bearing surface pressure on the piston skirt, which leads to 1
overheating that, in turn, may cause the skirt to crack.
- Finally, the "AE" model piston is a new design which is unproven.
Its operation, according to Delaval, is limited to testing in an R-5 test engine and field operation in a single engine.
This does not provide sufficient empirical data to reach positive conclusions about the "AE" piston.
Piston failure can have adverse conse-quences on the crankshaft and other components, and can degrade
{
EDG performance and even cause engine failure.
l 11.
Cylinder heads installed in the EDGs cracked during operation and were replaced with new cylinder heads of the same design but allegedly superior quality.
The design of the cylinder heads is inadequate to withstand the high thermal and mechanical stresses to which they are subjected during operation.
The i
thickness of the firedeck is uneven.
Delaval's design permits thickness variations from as little as.400 inch to as much as
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c,,..w,a-r,,--w-
...--y
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-., ~.. -, -,. -.
.861 inch in a firedeck with a nominal specification of.500 inch.
These variations result in increases in either thermal or mechanical stress due to gas pressure, create a stress riser in transition zones, and lead to cracking.
The water passages in the cylinder head do not provide for sufficient cooling, which exacerbates the problem of the uneven firedeck.
The studs holding the cylinder head in place are not properly spaced, which creates non-uniformity of stress; this again leads to failures in the higher stressed areas.
12.
The replacement cylinder heads are not of acceptable manufacturing quality.
Of thirteen replacement cylinder heads for the Shoreham EDGs visually inspected by the NRC Staff, one had a crack 3/8 inch long.
Delaval nevertheless found the cracked cyl-inder head acceptable because it had passed a hydrostatic test without leaking, and the cracked head was installed in a Shoreham EDG.
See NRC Inspection No. 50-322/83-25.
The County's metal-lurical consultant informed me that cracks tend to propagate and grow, and I believe a cylinder head known to be cracked is unac-ceptable for installation in EDGs.
Apparently none of the replacement cylinder heads were inspected for cracks by dye penetrant or magnetic particle examination by the NRC or LILCO.
13.
Additional cracked heads may be assumed to exist in the EDGs.
FaAA reported that (C]orrosion of the cylinder liner and piston crown was observed in cylinders of two engines EDG Crankshaft Failure Investigation, October 31, 1983, at 1-5.
FaAA does not indicate whether it determined the source of the
I corrosion, or the number of cylinders in which corrosion was noted.
Nor does FaAA indicate whether or how it inspected the cylinder heads in the EDGs for cracks after the crankshaft fail-ure.
On the basis of existing evidence, jacket water in the cylinder resulting from a cracked cylinder head may have con-tributed to the early failure of the undersized and poorly designed crar.kshaf t in EDG 102.
I 14.
The foregoing discussion of certain major components of the EDGs shows their interrelationship and how each is of inade-i quate design to satisfactorily withstand the operating stresses of the EDGs are their rated power.
The weaknesses of these major components may be exacerbated by their inter-relationship with each other and with other components during operation.
For ex-ample, water in the cylinder caused by a cracked cylinder head could adversely impact upon the pistons and the crankshaft.
l Another example is that a minor failure in the subassembly of the cylinder head could impair the operation of the head valves, which 4
in turn could overstress the crankshaft.
i 15.
Additional evidence that the EDGs are undersized for i
their intended functions and over-rated is that exhaust tempera-I tures in the EDGs are very high (approximately 1,100 degrees F.).
Further, the operating experience of the Delaval diesel engines on e
the M.V. Columbia evidences many of the same problems occurred as l
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with the Shoreham EDGs; the engines on the Columbia had to be de-
- rated.
Finally, the excessive vibration and variations in vibra-tion levels among the three EDGs may indicate over-rating.
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o Stanley G. Christensen
,i Subscribed and sworn to before me this Ji7 0 day of January, 1984.
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Notary P@lic I
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- IFU?fY t;~~/.'.Y.tPR '!:te of New Yosk l
Mo. 00/f78225 C mMW in Nossau county Cc erseen byrcs March 30,.!.9.g 4
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