ML20083A548
| ML20083A548 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/14/1983 |
| From: | Earley A HARMON & WEISS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8312200318 | |
| Download: ML20083A548 (9) | |
Text
v LILCO, Dccanber 14, 1983 DOCKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS!$bi DEC 16 A10:00 Before the Atomic Safety and Licensing Board gg EC'CEEiiNO SD'VE ER A NC'i In the Matter of
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LONG ISLAND LIGHTING COhPANY
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Docket No. 50-322 (OL)
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(Shoreham Nuclear Power Station,
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Unit 1)
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LILCO'S REQUEST TO SET SCHEDULE LILCO believes the time has come to set a schedule for the identification of any further diesel contentions and relat-ed discovery stemming from events that occurred on or after August 12, 1983.
Since that 6 ate, LILCO has furnished the County.with substantial information in the form of status re-ports, technical reports and opportunities for onsite inspec-tion of the diesels and their components. The County, there-fore, should certainly be able at this time to identify what further diesel contentions, if any, it wishes to raise.
Any such contentions must of course be rooted in events occurring L
on or after August 12 in order to be timely.
A brief history underscores the appropriateness of proceeding now with the i
l identification and particularization of further diesel conten-l tions, if any, and related discovery, i
l The crankshaft on diesel generator 102 failed over four
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full months ago on August 12, 1983.
At that time, LILCO, and l
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i F312200318 831214 PDR ADOCK 05000322 TSO3
presumably the County and Staff, were all completing testimony on the County's cylinder head contention then due to be filed on August 17, 1983. 'This was the only diesel generator issue required by the Board to be litigated prior to fuel load and the last safety issue to be resolved prior to issuance of a low power license.
As a result of the failure of the crankshaft, the Board granted LILCO's request for postponement of the cylinder head litigation pending completion of the investigation and issuance of the final report on the crankshaft failure.
This has now occurred; Failure Analysis Associates (FaAA), promptly retained to investigate the failure, completed its investigation by the end of October, and the FaAA final report on the crankshaft has been in the hands of the County and Staff since November 3, more than a month.
Quite apart from the FaAA report concerning the cause of crankshaft failure on diesel generator 102, LILCO has fur-nished the NRC Staff and the County with a number of other doc-uments and reports growing out of the LILCO diesel generator recovery effort.
These include the following:
1.
Woodward Governce Failure Analysis for Diesel Generator 102 dated October 28, 1983;.. - _ _ _ - -
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2.
Report of Reassembly Task Force for Die-sel Generator 101 dated October 24, 1983; 3.
Report of Reassembly Task Force for Die-sel Generator 102 dated September 25, 1983; 4.
Report of Reassembly Task Force for Die-sel Generator 103 dated September 22, 1983; 5.
. Preliminary Metallurgical Evaluation of Failed Crankshaft from DG 102 by FaAA; 6.
Interim report on Emergency Diesel Engine Connecting Rod Bearings by FaAA and memo-randum from FaAA dated October 13, 1983; 7.
Ultrasonic Evaluation Report of Diesel Generator Crankshafts by Nuclear Energy Services; 8.
LILCO Emergency Diesel Generator Inspec-tion Procedures for Diesel Generators 101, 102 and 103; 9
LILCO Emergency Diesel Generator Teardown Guidelines for Diesel Generators 101, 102 and 103; 10.
LILCO Strain Gauge Test Procedure --
Emergency Diesel Generator No. 101 crank-
' shaft; 11.
TDI report entitled " Field Torsiograph Test Report" dated October 5, 1983; 12.
Failure Analysis Report - EF-3060" by Parsons Peebles-Electric Products, Inc.
dated October 11, 1983 on the Emergency l
Diesel Generator 102 generator rotor; 13.
Diesel Generator Status Reports dated September 21, October 7, 20, November 3 and 17, 1983; 14.
Diesel Generator Master Plan dated August 23, 1983; 3-
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15.
FaAA memorandum on fractured cylinder head nuts dated November 25, 1983; 16.
FaAA report on the adequacy of the 13 X 12" crankshafts:
17.
Stone and Webster Report on Analysis of Lubricating Oil for the Diesel Generators dated December 6, 1983.
In addition to these documents and reports, the County attended a meeting between LILCO and the NRC Staff held on November 3 to discuss the results of the FaAA crankshaft inves-tigation and the basis for FaAA's final conclusion that the de-sign of the new 13" X 12" crankshafts adequately accommodates the cyclic torsional stresses expected during the life of the Shoreham diesels.
At this meeting, LILCO also described its plans for a design review and quality revalidation program for the diesels.
Moreover, LILCO provided the County and its consultants with the opportunity to inspect the diesels and their compo-nents on three occasions, September 3, 1983, September 27, 1983 and October 18, 1983.
These onsite visits permitted the County and its consultants to inspect visually the failed diesel gen-erator 102 crankshaft, the cracks in the crankshafts of diesel l
generators 101 and 103, the new crankshaft for diesel generator 103 installed and the new crankshaft for diesel generator 102 prior to installation.
In the course of these onsite visits, l l l
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i the County and its consultants also had the opportunity to in-spect various components of the engines, including the 101 baseplate and the repaired 102 baseplate, piston crowns and skirts, connecting rod bearings, main bearings, connecting rods, the engine locks, cylinder liners, cylinder heads, rocker arm assemblies, cylinder subcover assemblies, crankshafts, dis-assembled generators and front end gear train components.
Man-ifestly, therefore, the County has ample information to decide what, if any, additional timely diesel contentions it wishes to assert.
The LILCO diesel generator recovery effort is now com-plete in a number of major respects.
The three diesel genera-tors have been completely disassembled, new crankshafts installed and, where appropriate, other new components such as pistons have been installed.
Further, the engines have been reassembled and connected to their auxiliaries.
All three en-gines are scheduled to be running and in the test program be-fore Christmas.
Only three major features of the recovery ef-fort remain to be completed:~
(1) the preoperational test program, (2) the confirmatory torsional stress tests to be done on diesel generator 103, and (3) the diesel generator design review and quality revalidation program.
These features are all scheduled for completion by ih-end of February,1983, and -
will be followed by the integrated electrical test so that the j
plant will be physically ready for fuel load by the end of the first quarter of 1984.
I In summary, LILCO believes the time is now ripe for resuming the diesel litigation.
The County has been furnished with information sufficient to enable it to specify any further contentions it wishes to raise based on facts arising after August 12, 1983.
LILCO has completed major aspects of its die-sel recovery program, and the remaining steps are well un-derway.
Against this background, LILCO requests that the fol-lowing schedule for resumption of diesel litigation be set:
1.
County files motion, if December 301/
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any, to supplement con-tentions 2.
Other parties file responses, January 10 if any, to County motion 3.
Deadline for completion of January 'l further discovery on any new contentions 1
1/
If there are subsequent events that provide good cause for l
filing yet more contentions, the County may do so subject, as always, to the requirements of 10 CFR S 2.714.,
4.
Deadline for parties to January 31 agree, or to submit any dispute to the Board, on the identity of contentions ripe for-hearings 5.
Testimony filed on ripe February 10 contentions 6.
Motions to strike and February 14 cross plans filed 7.
Hearings begin February 21 Respectfully submitted, LONG ISLAND LIGHTING COMPANY a
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By '
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Co psel
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T.
S.
Ellis, III Anthony F.
Earley, Jr.
Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATED:
December 14, 1983
LILCO, December 14, 1983 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's Request to Set Schedule were served this date upon the following by first-class mail, postage prepaid, or by Federal Express (as indicated by an asterisk):
Lawrence Brenner, Esq.*
Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris
- Commission Administrative Judge Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Wsshington, D.C.
20555 Commission Washington, D.C.
20555 Dr. George A.
Ferguson*
Administrative Judge David J. Gilmartin, Esq.
Atomic Safety and Licensing Attn:
Patricia A.
Dempsey, Esq.
Board Panel County Attorney School of Engineering Suffolk County Department of Law Howard University Veterans Memorial Highway 2300 6th Street, N.W.
Hauppauge, New York 11787 Washington, D.C.
20059
.. Bernard M.
Bordenick, Esq.*
Stephen B.
Latham, Esq.
David A.
Repka, Esq.
Twomey, Latham & Shea U.S. Nuclear Regulatory 33 West Second Street Commission P. O. Box 398 Washington, D.C.
20555 Riverhead, New York 11901 Herbert H. Brown, Esq.*
Ralph Shapiro, Esq.
l.
Lawrence Coe Lanpher, Esq.
Cammer and Shapiro, P.C.
l Karla J. Letsche, Esq.
9 East 40th Street Kirkpatrick, Lockhart, Hill, New York, New York 10016 Christopher & Phillips 8th Floor James Dougherty, Esq.
1900 M Street, N.W.
3045 Porter Street Washington, D.C.
20036 Washington, D.C.
20008 Mr. Marc W. Goldsmith Howard L. Blau Energy Research Group 217 Newbridge Road 4001 Totten Pond Road Hicksville, New York 11801 Waltham, Massachusetts 02154 Jonathan D.
Feinberg, Esgy MHB Technical Associates New York State 1723 Hamilton Avenue Department of Public Service Suite K Three Empire State Plaza San Jose, California 95125 Albany, New York 12223 Mr. Jay Dunkleberger New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223
}u h ts n
Anthony F.
r l e'y, 'J r.
Hunton & Williams 707 East Main Street P.O.
Box 1535 Richmond, Virginia 23212 DATED:
December 14, 1983 l
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