ML20080L028
| ML20080L028 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/14/1984 |
| From: | Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080L010 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8402160223 | |
| Download: ML20080L028 (24) | |
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2/14/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
) '
In the Matter of ) .
)
f 'LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL
)
-(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY' S REPLY TO LILCO' S RESPONSE-TO SUFFOLK COUNTY'S MOTION TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS On February 7, 1984, LILCO filed its Response to Suffolk County's Motion to Admit Supplemental Diesel Generator Contentions (the;"LILCO Response"). The LILCO Response is highly unusual.
While it contains language which appears not to oppose litigation of the issues raised by the County's supplemental emergency diesel generator ("EDG") contentions, in reality it seeks to destroy those contentions and block the litigation of those issues. This
' Reply highlights significant aspects of the LILCO Response.
l'. LILCO Improperly Urges That Reliability Standards Be Lowered For The Shoreham EDGs. LILCO argues that in order to quickly permit LILCO to obtain a license for low power operation of Shoreham, this Board should apply standards for the performance and reliability of the Shoreham EDGs which are different and lower f
than those required by the technical specifications, the Shoreham FSAR, NRC regulations and the NRC Staff's interpretation of those 8402160223 840217 PDR ADOCK 05000322 PM g
l l
requirements. There is nothing in those requirements, and LILCO 1
cites not a single regulation or case, which suggests that. lower l EDG reliability standards apply for low power licenses.1!
LILCO's arguments in support of lower standards are, first, that only a single EDG operating at less than full power is needed duringflow power operation, ! and second, that LILCO's offsite power system is so reliable that concern over the onsite EDG system is unjustified. Without dignifying these arguments by a detailed technical rebuttal, we make the following points:
-(a) LILCO is currently required to have three EDGs of
-appropriate capacity and reliability. Those requirements are based upon technical matters, such as the different equipment powered by the different EDGs and NRC single failure and other technical criteria. Those requirements should not be changed by this Board, nor on the basis of unsubstantiated lawyers' arguments that proper contentions be denied.2!
(b)- NRC regulations (10 C.F.R. Part 50, Appendix A, Cri-terion 17) clearly state that the-onsite power system must be 1/ LILCO erroneously interprets a quotation from this Board's Memorandum and Order of June 22, 1983 (17 NRC 1132) as supporting this proposition. It is clear from the context of that quotation that this Board was simply explaining why a particular vibration problem, which testimony indicated was thought to be a long-term failure mechanism, need not be resolved prior to low power test-ing. The EDG problems addressed by the County's supplemental EDG contentions are so_ serious and pervasive that they clearly have a direct impact upon low power operation.
r 2/- LILCO even argues that no EDGs are necessary. See LILCO Response, footnote at 7.
3/~ It_.should be noted that the arguments in the LILCO Response about technical matters concerning EDG requirements are completely unsupported by affidavits of qualified experts, by other docu-mentary evidence, or by reference to any applicable regulations.
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independent from the offsite system. Nothing in the regulations permits lower standards for the onsite EDG system based upon pre-
-dictions of the likelihood of an offsite power failure. There-fore, the state of LILCO's offsite power system is irrelevant to the quality and reliability requirements for the EDGs.
Finally, the NRC Staff, having reviewed the many problems with the EDGs and similar diesels manufactured by Transamerica Delaval, Inc. ("TDI"),A! has expressly and unequivocably stated that unless and until those problems are adequately addressed, it will not recommend any license for Shoreham, including a low power license. See Transcript of Meeting on TDI Diesel Generators, January 26, 1984 (" Meeting Transcript") at 8 (Denton), 95-96 (Eisenhut). Clearly the Staff interprets the NRC regulations and other requirements for EDG capability and reliability to be the same for a low power license as for a full power license.
2! . LILCO Proposes That A Low Power License Be Granted After
' Inadequate Litigation of EDG Issues. The nature of LILCO's pro-posed lower standards for quickly obtaining a low power operating license is revealed by LILCO's proposal that litigation be limited to only-5 particular components of the EDGs, selected by LILCO:
replacement crankshafts, replacement pistons, replacement cylinder heads, replacement intermediate push rods, and the turbocharger thrust bearings. Thus, LILCO's standard is that if these 5 par-ticular components, all of which have suffered past failures,EI 4/. See Addendum to Suffolk County's Motion to Admit Supplemental Diecel. Generator Contentions, January 27, 1984.
5/ In Appendix A, p. 10 of the LILCO Response, LILCO disclosed (footnote continued)
.have;been adequately repaired or replaced, the EDG3 will~be deemed
.sufficiently capable and reliable to justify a low power operating
--license.
- ttis-standard, in view of the history of the EDGs, is woe-fully inadequate. .There is substantial evidence, as shown by the Laffidavits and voluminous detailed bases set forth in the County's 3
. Motion to Admit Supplemental Diesel Generator Contentions, that the:EDGs are-undersized and over-rated, poorly designed, and
-unsatisfactorily manufactured, and that because neither the EDGs nor replacement. parts for them were manufactured under a required effective quality assurance' program, there can be no confidence in EDG reliability.. EDG. failures could occur, and are likely to occur,;at unpredictable times. Accordingly,.the EDGs cannot simply beErepaired,.they must be replaced. These substantiated icontentions are'not addressed by LILCO's proposal to litigate .
'whether 5 selected components-(out of 218 component types) will work..
'LILCOLis thus proposing that this Board preclude a hearing of substantial safety' issues. In the face of the evidence of EDG '
deficiencies-and . failures to date, is this Board prepared to guarantee-that during low power operation the EDGs will not fail
.for. reasons other than failures of those 5 components? That is the : gamble that LILCO is asking this Board to take.
-(footnote continued from previous page) that:on' February 1 and February 5, turbocharger thrust bearings failed.on two.of the three EDGs. These latest EDG failures are presumably.the' reason LILCO has not made its list of particular components even shorter.
It is also a gamble which LILCO is likel'y to lose. By letter of February 10, 1984, LILCO informed this Board that after EDG 102 "successfully completed its 7-day endurance run," inspection dis-closed " linear indications . . . in the engine block." At a meet-ing between the TDI Owners' Group and the NRC Staff on February 10, 1984, Mr. Museler of LILCO, in response to questions, stated that these " linear indications" were found by visual inspection, consisted of 9 cracks in the cylinder block about one inch long each.in the area of 3 cylinders, and are similar to cracks found in the cylinder block of the TDI diesel on the ship M.V. Columbia.
LILCO'is inspecting the other two EDGs for cylinder block cracks.
Besides limiting litigation to only 5 components, LILCO has proposed contentions for the 5 components (Actachment B to the LILCO Response) which are completely unrealistic and designed to eliminate a fair hearing concerning each component. For example, LILCO's first proposed substitute contention is Whether there is adequate assurance that the replacement crankshafts for the Shoreham diesels will not fail due to torsional stresses imposed during anti-cipated normal and emergency conditions.
.Apparently LILCO believes it is acceptable if the replacement crankshafts fail for reasons other than torsional stress. LILCO's proposed piston contention is whether the replacement pistons "will not fail due to cracking in the ares of the crown to skirt connecting bolts." -LILCO would bar litigation of whether the design and manufacture of the pistons might result in other problems or failures.
LILCO's standard for a low power license -- that five selected EDG components are not likely to fail again in the same way as they did previously -- is totally unacceptable and unsup-portable.
- 3. LILCO Has Adopted An Unrealistic Piecemeal Single Component Approach To EDG Problems. Despite the evidence that the EDGs are complex machines with dynamic inter-related parta and must be addressed as a totality,5! LILCO's approach is to review the EDGs on a component-by-component basis only. Thus, as dis-cussed above, to obtain a low power license LILCO argues that it need only show that 5 particular components will not fail in exactly the same way. LILCO makes the argument, which we find incomprehensible, that concern about the overall design of the EDGs is adequately addressed by the litigation of 5 individual parts, and later by LILCO's design review of particular parts.
The County has submitted evidence that such an approach is not adequate. LILCO has submitted no affidavits or other documentary evidence to substantiate its claim that its piecemeal component approach will ensure the reliability of the EDGs as a whole.
Not only has LILCO misunderstood supplemental EDG Contention I, which contends that the EDGs are undersized and over-rated; it also has not grasped the express meaning of Contention II. Con-tention II not only states that various components of the EDGs are improperly-designed and, in specified cases, the design defi-ciencies have not been cured. It also shows, by reference to over 6/ See, e.g., Affidavit of Professor Stanley G. Christensen, Attachment 1 to the County's Motion to Admit Supplemental Diesel Generator Contentions.
f 50 cases of design deficiencies in the EDGs and in similar TDI diesels, that TDI's design work is so inadequate that There can be no reasonable assurance that the EDGs will perform satisfactorily in service and that there are not additional design deficiencies which will result in failures of other parts or components of the EDGs.
That is one reason the EDGs must be replaced, and cannot simply be patched up again. LILCO's proposed component review does not ad-dress the fundamental concerns expressed in Contention II.
- 4. LILCO Urges That EDG Litigation Proceed Without Important Evidence. LILCO's proposal is to litigate whether or not 5 particular components are likely to fail again, without waiting for the completion of the so-called LILCO Design Review ind Quality Revalidation ("DRQR") or the NRC Staff's evaluation of
.the EDGs. LILCO and the other members of the TDI Owners' Group have a strong, if puzzling, certainty that the outcome of the DRQR will show that the County's contentions are incorrect. As the TDI Owners' Group chairman has stated:
(W] hen we are finished with this program, we feel we will be able to defend the reliability-of these engines to anyone.
Meeting Transcript at 94 (McGaughy). But, if the DRQR is properly performed, it may find that the design and quality of EDG compon-ents are inadequate. A finding that, for example, the model "AE" piston (or some other component) is badly designed could be dis-positive of the case. Thus, proceeding with the litigation before completion of the DRQR could be wasteful, inefficient and even useless.
4 A
Even if no findings of the DRQR prove that the EDGs are inadequate, the DRQR and the Staff's EDG evaluations are certain to result in important evidence, either supporting or questioning the design or quality of the particular components being reviewed.
No doubt each party will want to reopen the hearing record to introduce such evidence which supports its positions, and will seek to relitigate issues affected by that evidence. In these circumstances a reopening and retrial would be totally justified, and in fact is inevitable. There is no legitimate reason not to defer litigation until all appropriate evidence has been devel-oped, thereby eliminating the waste and inefficiency of forcing the parties to litigate important safety issues with insufficient information.
- 5. Contrary To LILCO's Assertions, Preoperational Tests Are Inadequate to Disclose EDG Problems. In total disregard of recent experience, LILCO asserts that hearings for a low power license can be restricted to the 5 LILCO-selected components because LILCO believes that the prior extensive preoperational test program plus its new, enhanced preoperational test program will ensure that any problems that might af-fect diesel operation during low power testing will be identified [!]
LILCO Response at 11. LILCO will be unable to convince the County to share LILCO's new-found confidence in preoperational testing.
One need only recall that (to give only a few examples) LILCO's preoperational test program failed to identify the cracks in the crankshafts. It failed to identify the cracks in 23 of 24 pis-tons. It did not disclose design and manufacturing flaws in the
Accordingly, there is no reason to
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- connecting-rod. bearings.
believe that preoperational testing isladequate to reveal
. additional flaws in the EDGs.
- 6. LILCO Fails To Address TDI Manuf acturing And Quality Assurance Inadaquacies. LILCO's proposal to obtain a low power license ignores the County's Contentions III and IV. LILCO
' asserts that litigation _of the 5 components selected by LILCO would adequately address the issues of unsatisfactory manufac-turing and quality assurance of those components. That is simply not the case. -Even if LILCO's narrow, self-serving proposed com-ponent contentions were broadened, contentions III and IV could not bJ addressed in the context of 5 individual components.
?,ontention III does not only demonstrate that ennumerated EDG componentsJare poorly manufactured. It also shows, by reference
' to over 40 casesiof manufacturing defects in the EDGs and in similar TDI diesels, that TDI's manufacturing is so inadequate that-There can be no reasonable assurance that
) the-EDGs.will perform satisfactorily in service and that there are not additional manufacturing defects in the EDGs which
. will result in failures of other parts or components of the EDGs.
That is another reason why the EDGs must be replaced. LILCO's L
DRQR does not address this concern.
LILCO's, position regarding the failure of TDI to manufacture the'EDGs and their replapement parts under an effective Appendix B quality assurance program is equally startling. LILCO states
[I]t is important to note that all three Shoreham diesel generators were disas-sembled, inspected and reassembled by
[J . x g -
(LILCO; thus many concerns about TDI's QA i . programs may-not now be relevant [!]
ILCO Response at 11.(emphasis'added). We submit that this
. statement proves the opposite.
The County does not have any detailed information about LIICO's self-inspection of the disassembled EDGs. We do not know lwho conductedLthe-inspections and how they were-qualified, what
.was: inspected-and how,.who witnessed the inspections, what inspec-
-tion records were maintained, or what the precise results.of the
-inspections were. We do know'that defective cylinder heads are
.apparently.(still installed in the EDGs. See Christensen Affidavit .
at 6-8.. We do know that1 earlier this month, after LILCO's inspec-tions,fthe: turbocharger thrust bearings failed,in two of the three TEDGs'. :LI'LCO'. Response,; Attachment A at 10. We do know that des-
-pite.its earlier" inspections, LILCO anticipates that additional
' problems with the EDGs will be-disclosed during preoperational testing (but'.for unexplained reasons, LILCO does not believe such anticipated problems should:be litigated). Id. We do know that -
Llast week,.despite its earlier inspections, LILCO found cracks in
.the' cylinder ~ block.
This ~ record makes the County's' concerns about TDI's -
y, -
- unsatisfactory!manufacturina and inadequate quality assurance more
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relevant than"ever. 'If1EDG components are continuing to fail even
- afterlLILCO's disasseidly and inspection of each EDG, and even
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with the meticul'us o care with which LILCO is no doubt now oper-Jating.the'EDGs, then'there must indeed be either design defici-encies or manufacturing defects, or both, which LILCO and all of L _ . _ _ - - _ _ _ _ _ _ - - - - _ - - _ _ _ _ . -
its consultants and contractors were unable to detect. There must indeed be a serious quality assurance problem with the EDGs that cannot be cavalierly dismissed.
.But the LILCO Response does just that, arguing in a footnote that the issues of quality assurance and poor manufacturing are adequately resolved by LILCO's previous inspections (as described
-above) and by the DRQR. See LILCO Response at 12. In fact, the DRQR will not adequately address the quality assurance issue by
. verifying " key quality attributes." Contention IV states, in part, that because TDI did not have an effective Appendix B quality assurance' program (T]here can be no adequate confidence that the EDGs will operate reliabily
. ... and that additional parts and components of the EDGs will not fail.
'That is another reason why the EDGs must be replaced. " Adequate confidence" cannot be manufactured by a' review of " key quality attributes;" if that were all that was necessary, why bother with the regulatory requirements of-Appendix B?
Moreover, the lack of an effective Appendix B program at TDI raises-the question of whether the DRQR can even validly verify
" key quality attributes." Ineffective QA means that one component will~not necessarily be identical to another component of the same
' type. .Thus, the inspection or testing of " attributes" one will not r.ecessarily indicate the' nature of the same " attributes" in another. Moreover, the lack of quality in the EDGs means that there~are likely to.be latent defects in EDG components which
-would not be revealed even by a 1003 physical inspectyon. The
,yr ,
-post"-inspection failures of the turbocharger thrust bearings and cylinder block, demonstrates the likelihood of latent defects. .,
.7. LILCO=Has Misunderstood The County's EDG Contentions And
~Has Applied Incorrect Standards Of Admissibility. In Appendix A LLILCO;has hopelessly ~ confused the County's supplemental-EDG contentions _with-the specified bases supporting those contentions.
- These~ bases arecthe' factual reasons for.the County's belief that its' contentions'Cre true. It is well established that the County "need not state in its contentions the underpinnings or bases of
'the bases for its contentions.
See Houston Lighting and Power Company'(Allens-Creek. Nuclear Generating Station, Unit 1), AI AB-590, 111NRC.542 (1980); Mississippi Power and Light Company (Grand Gulf' Nuclear Station,! Units 1 and 2), ALAB-130, 6 AEC 423 (1973).
-In nearly every case in' Appendix A LILCO objects to a basis
- for'a contention,iand'not to the contention itself. LILCO thus challenges the-correctness of the factual assertion which forms the. basis of a contention or argues that the County has not ade-
'quatelyl explained the underpinnings for the specified bases. For
'. example,.LILCOLargues that Professor Christensen is incorrect in for.has.not fully explained assertions set forth in his affidavit (see, e.g., Attachment A at 1-2) or that the County is incorrect in!theLinterpretationiit has given to a particular factual matter
?(see,.e.g.,1 Attachment A at 19, para. 2, where LILCO argues that the County must:be bound by FaAA's interpretation of a defect).
These: challenges go to the merits of the contentions and are irrel'evant toJthe issue of admissibility. Whether or not a 4
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cpecified. basis is correct is decided either through summary disposition _or at'the evidentiary hearing.
In other' objections to bases for-the County's contentions,
-LILCO has simply misunderstood what is written in the contentions.
For example, in Attachment A at 15 LILCO objects to bases 2 and 4 of Contention _II,B because the design deficiencies were not found in the'Shoreham EDGs. Contention II.B expressly states that the listed bases were design deficiencies "in TDI diesel generators (essentially identical or similar to the EDGs) at other nuclear plants." They provide further support for Contention II, chat TDI's dismal diasel design record shows "there can be no reason-able assurance'that the EDGs will perform satisfactorily in service and that there are not additional design deficien-cies . .. ." Each basis set forth by the County is relevant to and' supports a contention, and each contention is relevant to the Shoreham-EDCs.
LILCO also. objects to some bases for the County's contentions because they' state a defect which LILCO claims has been remedied.
'See, e.g., Attachment A at 9. That a defect has been fixed does not mean-it.is irrelevant; the occurrence of each design defi-ciency or manufacturing defect, whether or not remedied, lends support to Contentions II and III -- that TDI's inadequate design
'and' unsatisfactory manufacture of diesel components in the EDGs and in similar TDI diesels indicate that there can be no reason-able assurance that the Shoreham EDGs are properly designed and manufactured.
.--,<i- . <r ,
In summary, LILCO's objections to the specific bases for the County's EDG contentions are either attempts to argue the correct-ness of. factual matters (as evidenced by the Kammeyer affidavit),
which may.be done only at the summary disposition or hearing stage,'or are the result of misreading the contentions. Each of the bases for an EDG contention is evidence supporting that con-tention. LILCO will have, presumably, a full opportunity to rebut that evidence at the hearing. It cannot, however, have that
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evidence stricken before the contentions are even admitted.
- 8. The Operating History Of Marine And Other TDI Diesels.
Similar To The EDGs Is Relevant. LILCO argues that evidence of problems with TDI diesels of different configurations and in other nuclear, marine and non-nuclear industrial applications must be disregarded as irrelevant. This position is a complete reversal for LILCO, and is without-foundation. In his affidavit attached to LILCO's Opposition to Suffolk County's Motion to Add an Emer-gency Diesel Generator Contention, May 16, 1983 (Attachment 3),
Mr.' Youngling of.LILCO testified:
The vendor has advised LILCO that the basic diesel engine in the Shoreham diesel generators has_been in production since the early 1950's. There are 97 diesel engines in this country that are essentially identical or very similar'to the Shoreham diesels.
Paragraph 5 (emphasis added). Mr. Youngling later testified to this Board that Some of the diesels that we have cited in our 97 are marine application diesels, others are stationary application for power' production and some are nuclear
-applications.
i Transcript of this proceeding, June 10, 1983 (" Hearing Transcript"), at 21,291.
1DI also has testified that TDI diesels in marine appli-cations referred to.in the County's supplemental EDG contentions are essentially the same as the engines at Shoreham. See Depo-
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sition of Richard A. Pratt of TDI, August 2, 1983, at 90-92,
_ copies of which are attached.1!
Finally, by Board Notification 84-018 dated January 27, 1984, the'NRC Staff transmitted to the NRC Commissioners and to appro-priate Boards and parties copies of the material concerning TDI diesels-in marine applications subpoenaed at the request of the Ccunty, stating This information, which supplements that provided in Board Notifications83-160 and 83-160a, is relevant to.all facili-ties that have diesel generators manu-factured by TDI . . . .
That information is the identical information referred to by the County in its supplemental EDG contentions.
9.. The LILCO Response Incorrectly Applies The Timeliness
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Standard. LILCO objects to many of the bases supporting the EDG contentions on grounds that particular events happened some time ago. However, this evidence forms part of the jigsaw puzzle that has lead to the EDG contentions. A particular defect in a TDI
' diesel which seemed minor a year ago becomes important when, as 7/ In. arguing the irrelevancy of the engines on the M.V.
Columbia, LILCO states that such engines "may have used heavy fuel." Attachment A to the LILCO Response at 3. In his deposition Mr. Pratt testified that tho'M.V. Columbia operates on number 2 diesel fuel. Pratt Affidavit at 99. In any case, the County believes-the problems with the Columbia engines are extremely relevant.
- here,cthe quantity of' defects demonstrates that TDI cannot properly design EDGs.
LILCO places the utmost importance on the timeliness criter-ion for the admissibility of the supplemental EDG contentions,,
arguing that the timelir.ess factor should be controlling." LILCO Response at 14. On this basis LILCO argues for the denial of many of.the. bases of the County's contentions. LILCO also admits, how-ever, that the County's contentions raise serious safety issues
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concerning-the overall design, manufacture and quality of the EDGs.
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The County agrees with the conclusion about timeliness which c LILCO stated to this Board in the context of a discussion about the admission of the County's initial EDG contention. Mr. Ellis,
. on' behalf of LILCO, said:.
I think'LILCO certainly would agree that while-the county has a heavy burden to establish' timeliness and we do believe that they are' untimely on at least portions of_the diesel contention, if not the whole thing, nonetheles (sic), this Board cannot let timeliness stand in the way of a serious problem if it sees a serious problem. The Board cannot of course dismiss a serious new problem or old problem simply because it was not timely raised.
Hearing-Transcript at 21,204 (emphasis added).
1 T
For the reasons stated herein, Suffolk County requests the Board to reject the proposals and arguments made in the LILCO
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Response and to grant Suffolk County's Motion to Admit Supple-mental Diesel Generator Contantions, as submitted.
Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
~, tne - '
Herbert H.' ow(
Lawrence C -Lanpher Alan Roy Dynner Douglas J. Scheidt KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County February 14, 1984
1
. UNITED STATES OF AMERICA 2i NUCLEAR REGULATORY COMMISSION '
a BEFORE MIE ATOMIC SAFETY AND LICENSING BOARD W- 3 l 4 ,
5
---o00---
6 7 In the Matter of I
8 LONG ISLAND LIGHTING COMPANY i (SHOREHAM NUCLEAR POWER STATION, No. 50-322 0.C.:
9 UNIT 1.)
10 ' Deposition of ,
RICHARD A. PRATT 11 '
August 2, 1983 i
12 VOLUME I Pages 1 - 157 13 -lj ,
14 15 i ,
, 16-17 .
I s
18 19 i t
20l 21 .
I 22 23 24 25 26 Reported by ADELE I. NOLAN, CSR No. 1641, ;
LESLIE TANIMURA-WONG, CSR No. 5796 !
-27 l L 28 :
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ggg.
%ee-M9hAN REPORTING SERYlEE INC.
1533 he Speet. San Francisco. CA 94109
'eepnone id:St 928 8001
1 ,
248 BMEP, which ia roughly 10 pnrcent moro load than tha hnado 2 {, at LILCO will see.
Therefore, they are stressed higher than the heads of h
s-3- ,
4 LILCO will be stressed, and I will state again that the 19,000 5
hours that they have accumulated -- now that's 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per 6 hull, per engine, it's not 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> distributed over two 7 engines, so that's two engines that have 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> each on 8* them.
9 .
If you are going to distribute it over the entire number I 10 , of engines , it would be 38,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> total.
11 l G The Pride, you said, had two engines at 9,000?
12 li
- A Right.
13 ! 4 The Star, I think you said, had two engines at 6,0007 :
i A
14 - Correct. ,
15 g The Spirit has two engines at 4,0007 ;
16 '
A. Uh-huh. 1 17 g And the --
18 A. Columbia.
19 ,
G And the refitted engine on the M.V. Columbia has about '
t :
20 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />; is that correct?
21 A. Correct.
22 What was that last figure? I'm sorry.
MR. ELLIS:
23 THE WITNESS: Forty-five hundred hours.
24 MR. DYNNER: 4 Do I take it that, in your view, the 25' operation of the cylinder heads in the marine application is 26 relevant to the reliability of the cylinder heads in a nuclear 27 application?
20 A. Yes. That would be my opinion.
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Te esace.a'5 92! W,1
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I baco that upon tha'f'act that the strains that a cylinder i
2 { head . sees are primarily related to firing pressures. '
The engines at LILCO operate at 225 BMEP, on number 2 k 3 4 diesel -- yes, they do. ,
5 They are required to start rapidly, but they are also 6 kept warm and near operating temperature, and the rapid start of 7 an engine does not impose severe stresses on the heads, in my s
8 opinion.
q 9: The engines. aboard the Spirit of Texas and the other two ,
1, -
10 i Texas ' class vessels operate at 248 BMEP, roughly 10 percent I
11 greater horsepower than the LILCO engines were.
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l 12: They operate on degraded fuels, residual fuels, which are 13 hard on an engine. ,
14 They are overloaded to start with, because the propellers 15 bf or those ships' are too big and therefore -- I'm sorry, one other f:
L} .16 thing -- they are a direct reversing engine, which means every ,
17 time that ship has to maneuver, the engine has to stop, reverse !
18 direction, and start rapidly, so they get numerous starts and 19 stops on'these engines, and I would consider that application f.
20 to be far'more severe, therefore, than the LILCO application 21 would be.
22 O Aside from those differences, are these engines 20- essentially the same as the engines at Shoreham? l A Yes. The engines on the Texas class vessels are I !
24 *
' 25 V engines. .
l 26 The Shoreham is an in-line; however, they are both i 27 17-inch bore, 21-inch stroke engines that use the same pistons, ; <
28 the same cylinder heads, and see the same firing pressures and ;
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t 1 !Op2 rating otracccc.
1 2l O And the cylinder heads on the marine engines, are they
,= =
55h 3 ,1 the same as the cylinder heads that are -- the new cylinder heads 4 l that are installed and to be installed at Shoreham?
5 A Yes, they are, with the exception that they have a 6 built-in relief valve as required by ABSS, will open at 1800 7 pounds firing pressure.
8i G When you say "they," you mean the ones at Shoreham?
9 A The ones in marine.
10 0 The ones in marine. And would that change -- have any 11 impact on the function or operation of the cylinder head --
12 A None.
13., g -- in terms of its reliability?
14 A None, none.
15 G Can you estimate for me, or do you know precisely how l i
s.
16 many of the 636 cylinder heads have no operating time on them?
17 MR. ALDEN: No operating time?
18 MR. DYNNER: No operating time.
19 THE WITNESS: Well, very few, because even though the i
20 cylinder heads are installed on new construction engines, they ,
21 have nevertheless had to go through a four- to six- to eight-houri
. I 22 factory test, so they at least all have that much operating time 23 on them, and of that quantity, I would say that 90 percent of 24 that 636 has at least that many.
25 MR. DYNNER: 4 You mentioned that you excluded cylinder 26 heads with what you, I think, referred to as minimal number of l 27 !
hours on them?
28 A Yes.
MTM.
51E WGLAN REPORTlWE SERYlCE INC.
'%3 Pine St<*et. San F*aetsca CA 94:09 te eenone 4:$,323.q001
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Ecfore.the Atomic Safety and Licensing Board
),
In'the Matter of )
)
LONG. ISLAND LIGHTING COMPANY. ) Docket No. 50-322 0.L.
)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S MOTION FOR
' LEAVE.TO REPLY TO LILCO'S RESPONSE TO SUFFOLK COUNTY'S MOTION TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS and SUFFOLK COUNTY'S REPLY TO LILCO'S RESPONSE TO SUFFOLK COUNTY'S MOTION TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS, dated February 14, 1984, have been served to the following this 14th day of February 1984 by U.S. mail, first class, except as otherwise indicated.
Lawrence J. Brenner, Esq.* Ralph Shapiro, Esq.
. Administrative Judge Cammer and Shapiro Atomic Safety and-Licensing Board. 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Dr.' George-A. Ferguson* Howard L. Blau, Esq.
Administrative Judge- 217 Newbridge Road Atomic Safety and Licensing Board Hicksville, New York 11801
' School of Engineering Howard University #W.. Taylor Reveley, III, Esq.
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~250 Old' Country Road 3045 Porter Street, N.W.
'Mineola, New York 11501 Washington, D.C. 20008
Mr.,' Brian McCaffrey Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham a Shea 175 East Old Country Road P.O. Box 398 Hicksville, New York 11801 33 West Second Street Riverhead, Now York 11901 Jeff Smith Marc W. Goldsmith
.Shoreham Nuclear-Power Station Energy Research Group, Inc.
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[.
L c.* 1
= Stewart'M. Glass, Esq. Fabian Palomino, Esq.#
Regional Counsel Special Counsel to the Federal Emergency Management' Governor
' Agency . Executive Chamber 26: Federal Plaza Room 229 New York, New York 10278 State Capitol Albany, New York 12224 Gerald C. Crotty, Esq.
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Guggenheimer & Untermyer 80 Pine Street New York, New York 10005 Alan Roy Dy nepF KIRKPATRI , LOCKHART, HILL, CHRISTO HER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATE: February 14, 1984
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