ML20092P260
| ML20092P260 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/02/1984 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| OL-4, NUDOCS 8407060111 | |
| Download: ML20092P260 (73) | |
Text
,
ekk LILCO, July 2, 1984 CO M ETED LELCC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 JUL -5 P!2:17 Before the Atomic Safety and Licensing' Beard! [, '
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In.the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-4
)
(Low Power)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
SUPPLEMENTATION OF JUNE 22, 1984 ORAL ARGUMENT At the oral argument on June 22, 1984, concerning vari-ous discovery matters, the Licensing Board granted leave to the parties to supplement the record by supplying direct quotations from pertinent portions of the transcripts of depositions.
Ac-cordingly, LILCO hereby supplements the record as follows.
Copies of the referenced transcript pages are attached.
A.
In Support of LILCO's Motion For Protective Order The following transcript references from the deposition testimony of Michael Dirmeier and Jamshed K. Madan on June 14, 1984, indicate that the matters in Suffolk County's Second Dis-covery Request pertain to the issues of LILCO's financial qual-ifications to operate Shoreham, che impact of LILCO's financial condition on its ability to conduct low power testing and a comparison of the costs of decommissioning Shoreham,.if a full M07060111 840702 PDR ADOCK 05000322 g
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i. power license is not granted, with any economic benefit from
.early operation, all of which were described in LILCO's Motion for Protective Order and oral argument in support of that Mo-tion on June 22:
June 14, 1984 Deposition of Michael Dirmeier Page Description 1/
14 Interrogatories are not limited to economic or financial claims made by LILCO in its application for exemption.
Rather, they were designed to obtain information con-cerning financial, economic and public benefit aspects (as defined in his deposi-tion) of LILCO's application.
June 14, 1984 Deposition of Jamshed K. Madan Page Description 28 Will investigate economic consequences if Shoreham does go on line, if Shoreham does not go on line and, the cause for greatest concern, possible need to decontaminate the plant if Shoreham doesn't go on line.
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29-30 Will also investigate possible incremental expenses attached to-fuel loading, need for additional personnel and the need for additional security.
Will also analyze LILCO's ability to respond to some kind of major financial disaster, such as a hurricane, in light of its-limited cash resources.
The uncertainty surrounding Nine Mile 2 is also a concern.
1/
All descriptions herein are paraphrased for brevity.
The pertinent transcript pages are attached.
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1
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99-100 Does not know why LILCO's periodic finan-cial reports since 1983 are needed for his analysis, but reviewing LILCO's general cash situation and events over 1983-84 could be critical to a cost-benefit analysis and to the potential issue of how LILCO's cash position may change.
This is pertinent to LILCO's financial ability to operate the plant.
Second Discovery Request 3
seeking financial runs, reports, analyses L
showing actual and projected cash flow revenue expenses, capitalize cost and capitalize expenses is crucial to his p
analysis because it reveals what the capital structure looks like and how the cash flows.
This is relevant to the Company's financial ability to operate the plant and go into low power testing.
109 Through interrogatories'and depositions, hopes to find out what LILCO's response will be to various scenarios (based on its 5
financial situation, whether finances prompt certain cutbacks, etc.).
110 Purpose is to discover whether or not any safety problems will arise from the Com-pany's financial condition.
123-24 Second Discovery Request to LILCO is re-sponsive to all the issues Madan intends to investigate.
g B.
In Support of LILCO's Request for Supplementation of Discovery Responses The following references to deposition transcripts sup-e
[
port LILCO's assertion at the June 22, 1984 hearing that pro-a posed wi.tnesses on behalf of Suffolk County had expressed no i
final opinions during their depositions with respect to the substance of their testimony:
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. June 7, 1984 Deposition of Aneesh Bakshi Page Description 43 Has formed no conclusion as to whether or not the particular model EMD diesel generators at Shoreham are suitable as an emergency power source.
63 Has reached no conclusion concerning the EMD~ diesels at Shoreham or the method in which LILCO intends to use them.
173 Does not know if there z.re any codes or standards applicable to the Shoreham EMD diesels with which they do not comply.
174 Has no opinion as to whether EMD diesels are able to reach their required speed.
176-77 Has no opinion as to whether Shoreham EMD die'sels have the ability to take J
load and has not even formulated a plan for review of the issue.
178 Has reached no conclusion or opinion con-cerning the reliability of the Shoreham EMD diesel components.
181 Has no opinion as to whether the Shoreham EMD diesels are safe enough for their intended use.
182 Has made no design calculations concerning whether stress levels on the Shoreham EMD-diesels pose any problem.
187 Has no opinion yet on how frequent surveil-lance. testing could be made in-order to ensure reliability.
193 Has formulated no opinion concerning the reliability of the EMD diesels based on their operating history.
198 Does not know if he will express an opinion concerning whether or not Shoreham'EMD's
F 2 are capable of powering the emergency load which may be necessary to mitigate an accident.
June 4, 1984 Deposition of G. Dennis Eley Page Description 33 Has formed no conclusions concerning the reliablity of Shoreham EMD diesels.
42 Has no opinion concerning the running reliablity of the EMD diesels at Shoreham.
42-43 Has no opinion right now concerning un-availability of diesels due to mechanical failure.
55-56 Has performed no calculations concerning the ability of the EMD diesels to reach the necessary speed.
58-59 Has no opinion concerning the reliability of any particular components of the EMD diesels at Shoreham.
63 Has no opinion concerning the battery starting units on the EMD diesels at Shoreham.
June 11, 1984 Deposition of Christian Meyer Page Description 36 Dr. Meyer and Dr. Roesset have not yet de-cided what analyses they will be performing and have not yet divided tasks among them-selves.
62 Has reached no final opinion as a result of his visit to Shoreham.
77-78 Has reached no opinion concerning onsite power sources which consists of a gas turbine, transformers, switchyard, four mobile l
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' # \\ diesel generators and their interconnecting parts.
79 Has no opinion concerning transmission line systems connecting onsite equipment to local substation and no opinions concerning
' substation components used to switch or control' incoming power to the site.
a 80
,Has no opinion concerning fuel oil storage l
, tanks.
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l 80-81 LHas bo opinion concerning physical elec-j r.
trical conn 9ctions.
i l
143-44 Has fodmod'no opinion concerning items he will analyze in phase two of his work.
s, 144-45' Has not'yet begun'his phase two analyses.
t i
s June 12, 1984 Dep,sition of Robert K. Weatherwax j
Page Description 85 Has done nothing to determine what the potential failure mechanisms are in connec-tion'with the components connecting the gas
~ turbine and the bus.
182-83
' 'Has reached no final opinions with respect l
s to LILCO's application for a low power _
license in any aspect of his review.
~
June 12, 1984 Deposition of Mohammed El Gasseir Page 5
Description 48 Has formed no = opinions, concerning low power license application which he is reviewing.
Has not been asked to form any opinions.
Does not know if he will be expected to testify and offer any opinions.
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. June 14, 1984 Deposition of Jamshed K. Maden Page Description 52-53 Has not " reached a final analysis" on whether there are any short-term higher costs of securing financing by LILCO as a result of the delay in bringing Shoreham on line.
66 Has reached no opinions yet as a' result of his work.
80-81 Has reached no opinion concerning the cost to LILCO of a low power license.
June 14, 1984 Deposition of Michael D. Dirmeier Page Description 16-17 Has no final conclusion about what a comparison of early testing vs. late testing will reveal.
52 Has not reached any opinion as to whether there would be any delay costs to LILCO as a result of delaying low power testing.
60 Has no conclusions with respect to the savings of oil by bringing Shoreham on line.
84 Intends to finalize his opinions by July 15 or 16 so they can be filed.
In addition to the above depositions, and in order to keep the Board fully advised, LILCO provides the following ref-erences to the deposition of Gregory C. Minor taken June.26, f
1984, wherein Mr. Minor stated that he, too, had no opinions:
I 4
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e 8-Page Description 46 Plans for MHB testimony "not finalized" and participation in testimony by Robert Weatherwax "not defined at this time."
51 SERA (Mr. Weatherwax) has not yet reached any conclusions and Minor does not know the extent of his participation in SERA testimony.
55 SERA testimony will be finalized by its due date.
56 Does not know whether Dr. Roesset will testify and does nct know when a decision will be made concerning his' testimony.
57 Minor "may be involved" in the seismic testimony.
59 Counsel for Suffolk County confirms that there is no cercainty'as to whether Dr.
Roesset will be a witness.
Dr. Meyer has reached no opinion.
73 Minor is not aware of any opinions by the seismic witnesses yet.
96-97 Bakshi and Eley have reached no firm con-clusions at this time.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY A
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Yob'e rt. M. Rolfe W
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Anthony F. Ehrley, Jr.
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Jessine A. Monaghan Hunton & Williams P. O.
Box 1535
-Richmond, Virgidia 23212 DATED:
July 2, 1984-2 t
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LILCO, July 2, 1984 m=7 u;idC CERTIFICATE OF SERVICE
'84 JL1. -5 R2 :17 In the Matter of LONG ISLAND LIGHTING COMPANY : n....,, g..
(Shoreham Nuclear Power Statioa, UnitG)%d.'. $U V i Docket No. 50-322-OL-4 (Low Power)
BRANCH I hereby certify that copies of LILCO's Supplementation of June 22, 1984 Oral Argument were served this date upon the following by first-class mail, postage prepaid:
Judge Marshall E. Miller Fabian Palomino, Esq.
Chairman Special Counsel to the Atomic Safety and Licensing Governor Board Executive Chamber, Room 229 U.S. Nuclear Regulatory State Capitol Commission Albany, New York 12224 Washington, D.C.
20555 Herbert H.
Brown, Esq.
Judge Glenn O.
Bright Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Kirkpatrick, Lockhart, Hill, Board Christopher & Phillips U.S. Nuclear Regulatory 1900 M Street, N.W.
Commission Washington, D.C.
20036 Washington, D.C.
20555 Honorable Peter Cohalan Judge Elizabeth B. Johnson Suffolk County Executive Atomic Safety and Licensing.
County Executive / Legislative Board Building U.S. Nuclear Regulatory Veterans Memorial Highway Commission Hauppauge, New-York 11788 Washington, D.C.
20555 Martin 1Bradley Ashare, Esq.
Eleanor L.
Frucci,'Esq.
Suffolk County Attorney Atomic. Safety and Licensing' H. Lee-Dennison Building Board Veterans Memorial-Highway U.S. Nuclear. Regulatory
-Hauppauge, New York 11788 Commission Washington, D.C.
20555 I
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Edwin.J. Reis, Esq.
Jay Dunkleberger, Esq.
U.S. Nuclear Regulatory New York State Energy Office Commission Agency Building 2 Washington, D.C.
20555 Empire State Plaza Albany, New York 12223 Stephen B.
Latham, Esq.
John F. Shea, Esq.
Mr. Martin Suubert Twomey, Latham & Shea c/o Congressman William Carney 33 West Second Street 1113 Longworth House Office Riverhead, New York 11901 Building Washington, D.C.
20515 Docketing and Service Branch Office of the Secretary James Dougherty, Esq.
U.S. Nuclear Regulatory 3045 Porter Street, N.W.
Commission Washington, D.C.
20008 Washington, D.C.
20555
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4 hte O. C^Tl'i.lt, -
' Anthony F.g/Earley, Jr. / /
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
July 2, 1984
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1" Dirmeier deposition 1
financial aspects of the low power -- the application
(
2 for ex emption?
3 A
Well, I don' t know that I would say they were 4
limite d to that.
They are designed to provide us with 5
the inf ermation we need so that we can present a 6
com ple te case regarding the financial and economic and 7
p ublic benefit aspects of LILCO 's applications.
8 0
Tell me what financial aspects you're locking 9
at wit h respect to LILCO's application.
10 A
Vell, I believe Er. Eadan testified to this 11 this morning, and we can go back to it all again.
12 MR. SEDKY:
Given your understanding.
13 THE WITNESS:
There are cost-benefit aspects 14 of the company's application.
There are financial.
15 aspects of initiating the testing when you are faced 16 with potentini reorganizatien.
There is analys.is cf th'e 17 company 's financin g plan.
There is conce rn as to the 18 compan y 's situation where costs exceed revenues, and 19 there needs to be analysis of that.
Sc there are a 20 number of financial areas we will be exploring.
21 BY MR. ROLFE:
(.Pesuming) 22 2
You mentioned the cost-benefit application.
t ALDERSON MEPORTING COMPANY,lNC..
30 F ST, N.W WASHINGTON, D.C. 20001 G104 626930C
Dirmeier deposition 16 1
those are the three leading candida tes f or considera tio n
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2 at this time.
3 Q
How will you be comparing early testing wi th 4
late t esting, both assuming ultimate operation?
5 A
Well, you ha ve financial projecticns of ths 6
situation over a peri',d of years with early testing and 7
financial projections ever a series of years with la te r 8
t es tin g, and you compare these, analyze them.
9 2
Have you done that kind of analysis yet?
10 A
At this time?
11 0
Yes.
12 A
In this proceeding?
13 Q
Yes.
14 A
No.
15 0
Have you done it in any other proceeding?
16 A
For testing?
17 2
Yes.
18 A
No.
19 3
Have you done any -- do you have any 20 preliminary opinions or conclusions as to what that 21 comparison will show?
22 A
Well, no conclusion other than the fact that.
L ALDERSON REPORTING COMPANY,INC.
20 F ST., N.W WASHINGTON, D C. 20001 (202 628-9300
i Dirmeier deposition 17
{.
I we hav e read IIlCO 's claim that there's approximately a
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2 445 million s ronth benefit from early operation of the 3
plant.
That $45 million consists of about T26 millien 4
of ASC and as ytt an undocumented $19 million -
5 dif fer ence.
And it's a preliminary conclusion that the 6
ASC is cf no real tenefit in terms of present value.
It 7
doesn' t change the value today of that plant.
And we 8
need to analyzo the rest of it.
9 0
Do you know what the rest of it consists of?
10 A
That's the subject of discovery with the 11 com pan y.
It would include such thingc as continued 12 mainta nance for lubrication of pumps, continued purchase 13 of material and supplies, ongoing testing of systens 14 tha t s re alread y in place, continued employment of test and then 15 person nel who even tually would operate 16 eventu ally operste the plan t, if it gees to testing and 17 operation and all the other activities that are going on 18 at Sho reham at this time.
19 Q
Can you explain how tho se f actors will dif fer 20 betwee n early testing and later testing?
21 A
Well, that is the subject of the discovery.
22 We are seeking 'inf orma tion f rom LILCO so that, in f act, f
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4 ALDERSON REPORTING COMPANY.lNC.
20 F ST, N.W WASHINGTON. D.C. 20001 QO2) 828-9300
Dirmeier deposition 52 C
1 the po tential f or changing conclusions.
(
2 Q
Do you have any opinion now as to whether 3
there would be any delay cost to LILCO as a result of 4
delaying low power testing?
- 5 A
When you said delay cost to LILCO, you mean to 6
LILCO's investors and not to LILCO's ratepayers?
7 0
Yes.
8 A
I don't have a conclusion as to that, because
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9 one of the factors, as we discussed earlier, is if ycu 10 delayed low power testing f rom July to November, that 11 may or may not delay full power operation.
It may not 12 have any effect on f ull power cperation, for that 13 m a t te r.
So one does not necessarily proceed to the 14 cther.
15 Ce rta inl y, if you said to me assume that the 16
!!SC or whatever authority it is, is ocino to give us an 17 order in December that says the diesels are no prorlem, 18 the ev acuation plan is no problem, and if there were any 19 o t h s.r problems, there are no problems, ckay?
And assume 20 that low power testing takes three months.
Then if I 21 assume away all the problems, then delaying of a 22 decision to low power test to Decem ber, may dela y k.
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ALDERSoN REPORTING COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.C. 20001 (202) 628 9300
Dirmeier depositi.on 60 1
and I haven ' t rela ted this computation to LILCC's 1Cu
(
2 power exemption or applica tion f or exemption.
3 0
Why did you perform this calculation?
4 A
LILCO somewhere had said it would save 7.5 5
millio n barrels and I was interested in -- one of the 6
questions that was in m'y mind was wha t ca pa city facters 7
did th ey assume.
So I said, well, th a t 's 48 percent of 8
the oil.
If I assume a 65 percent capacity factor, how 9
much is that of electricity?
Are the two numbers 10 approximately the same percentage?
11 No, they're not.
It is really a meaningless 12 computation, to be frank with you, because it 's not 13 necess arily clear that a 65 percent capacity factor, 14 while it would produc'e 34 percent of the electricity, 15 would or would not produce 48 percent of the oil 16 consum p tion.
They don't necessarily have to relate to 17 each other.
18 It is a computation I made and it was in one 19 of my notebooks, and rather than not give it in response 20 to the data request, we cave it in the data request.
I 21 am really not prepared to reach any conclusion based on 22 that romputation.
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r ALDERSoN REPoRnNG COMPANY.INC. -
20 F ST., N.W., WASHINGTON, D.C. 20001 (200 628-9300
e Dirmeier deposition ga r(
l 1
County ?
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2 A
I expect the finalization to te done -- it has 3
to be done so we can file it July 15th or 16th.
I 4
believ e that 's when the filing is required.
5 It is in part dependent upon the availability 6
of inf ormation from LILCO, in response to the req ue sts.
7 That will certainly have a significant impact as to when 8
we can complete our analysis.
9 3
You're f amiliar with the document r equ est th a t 10 has been served on LILCO, identified as Suf folk County 's 11 second document request to LILCO?
12 A
Yes.
13 0
Have you attempted to find a.ny of the 14 inform ation requested in that second document request 15 els ewh ere ?
16 A
Well, most of that information is not 17 availa ble publicly to my knowledge, or I don't-know 18 where it is available publicly.
Some of it might be 19 availa ble in the rate case, but very little would be becaus e my memory of the ra te case was that it 20 21 was -- subs tantial discovery preda tes ' the starting poin t 22 ~ for most of the information requested there.
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ALDERSON REPORTING COMPANY,INC..
20 F ST., N.W., WASHINGTON, D.C. 20001 (202) 628-9300
U-Madan dep. 6/14/84 28 1
closely to the financial issues, se I.will try and 2
1solat e them, if I could.
3 There is certainly a questien of the, as far 4
a s th e economic issue goes, the a~orall exposure of the 5
low power process in terms of dollars and cents, 8
de pend ing upon the varicus cutccmes that are likely in 7
the ultimate resolution of Shorenam.
8 By that I mean if Shoreham does not go on 9
line, is not licensed, I think you have a certain stream 10 of dollars that flow'out of th a t, a series of events, et 11 cetera, th a t we would analyze.
If the plant does g.c on 12 line w e clearly have a different stream.
The 13 relaticnship of the low power testing at that point is 14 relevant in terms, at least generally at this point and 15 in terms of what we know, we clearly would have to 16 develo p our thinking as we vent along in this area.
17 But the area of greatest concern' would be the 18
' irradia tion of the plant, the decommissioning., the 19 deccntamination in the event the p-rocess was started and 20 a fina l favorable resolutien of the Shorehan issue from 21 LII CO's standpoint was not obta'.ned.
So we have te 22 presen t in ef f ect what the exposure would he and we hav e ALDERSoN REPORTING COMPANY,lNC.
Madan dep.
29 1
interrogatories ou t to LILCO to provide us informatica 2
with r egard to what their estimates are on 3
decentamination and decommissioning in th a t likelihced.
4 0
Are there other economic issues, or does that 5
sum up all of them you perceive now?
6 A
As I say, now tha t is clearly a major econcaic 7
issue, as we would see it at this point.
There are 8
oth er -- if we use the broader term financial issues, a t 9
this p oint there are clearly a number of them.
The to actual expenditures of dollars and the time f rame cf 11 thosa dollars are also significan t to us in terms of an 12 evalua tion and we are not quite sure which way it wo uld 13 go.
14 In this regard, it is~our understanding that 15 once the f uel is leaded tha t there would perhaps be 16 additicnal incremental expenses in terms of additional 17 personnel on site, in terms of aaditional security tha t 18 might be involved in the operation and clearly once you 19 do tha t and for whatever reason the licensing process M
drags on, you have these ecsts, if you would, on a 21 con tin u'ing basis that we would have to evaluate and Z2 determine as to what the exposure in that regard would ALDERSoN REPORTING COMPANY,INC.
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9 W'TM T
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. 30 Madan dep.
1 be.
2 With regard to other issues in terms of a 3
financial nature, there is the issue of cash.
Every 4
projec tion that LILCO has made to date shows LILCO 5
runnin g cut of cash and the implications of that en the s' e a s f airly critical.
What 6
licen s ing process we e
happen s within the process as to how close they are to 7
8 the ma rgin, everything they have filed to f ar indica tes 9
the re is no more room.
Everything has been cut te the to bone.
11 And - to the e xte n t tha t you have, as Mr. Sadira 12 says in his Track II'testimcny, if you have a major 13 financial aisaster of some kind -
you have a storm, yo u 14 have a hurricane, you have something like that you 15 are so close to the edge that it's difficult to see 16 whe re the cash resources would. come from to address that 17 kind o f situation.
18 The other major area of grest concern te us 19 from 3 financial viewpoint'is the uncertainty 20 su r rou nding the situation a t Nine Mile 2.
Given that 21 the company has in ef f ect a nnounced 'that it will not 22 - continue to make f urther direct payments, that it has
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4 Madan dep.
52 s
1 f orerists the supply end of it as opposed to the price 2
end of it?
3 A
No.
4 2
So you would rely oa outside expertise for 5
' tha t?
6 A
Yes.
7 2
Have you considered in arriving at the view 8
tha't you expressed before that there may not be any rea l 9
d elay costs, which is a shorthand var of expressino it?
10 I don ' t mean to mischaracterize wha t ycu said.
I'm jus t 11 using it as a shorthand phrasing.
12 A
Say that again - - tha t there 's not been a 13 d elay cost?
14 MR. SEDKY:
He hasn't finished his question.
15 BY MR. ROLFE (Resuming) 16 2
Let me start that one over.
In expressing th e 17 opinion you reached before that you don't think it's 18 accurate that there has been a delay cost or will be-1 19
' d elay ccst, have ycu censidered whether there are any 20 short-term higher costs of securing financing to LILCO 21 as a result of.the delay in getting this plant in
. zt service and putting the costs in the rate base?
t
' ALDER $oN REPORTING COMPANY,INC. '
Madan dep.
53 1
A We have thought about that.
We clearly ha ve 2
not re ached a final analysis on the issue.
It is 3
som eth ing that has many components tha t we're going to 4
have to think about.
We will take that into account.
5 0
Just in a becad sense, are there any 6
additional issues that you plan to look at other than*
7 those you have described for me so f ar?
8 A
No.
I think we have pretty much hit on the 9
major ones, at least in terms of priority and to impcrtance.
I think what I listed was where our 11 emphasis would be.
12 3
Looking at those issues, wha t a re.ycu trying 13 to det ermine ?
14 A
I think we are trying to determine and p resen t 15 what the end result will be' for each one of then, and 16 perhaps it is p robably apprcpriate to go th ro ugh each 17 one item by item.
In general we would try to see en th e 18 economic issue as to what the cost is and what the 19 ben efi t is.
I think that again is the shorthand we went a
thrcug h a little bit earlie r as te ' wha t the expcsure 21 might be as against the potential benefits, if a ny.
22 So that would be a self-contained analysis
- ALDERSON REPORTING COMPANY,INC.
Madan dep.
66 1
A Am I aware of that?
2 0
Yes.
3 A
No, I'm not specifically aware of that.
4 0
So you are net aware of whether that 5
decision -- strike that.
6 Have you reached any opinions yet as the 7
result of your work?
8 A
No, other than the concerns we spoke about, 9
and they would be concerns in the area we have been to throug h now a couple of tim es.
11 0
Tell me what you have done thus far since 12 being asked by the County to undertake your consulting 13 work?
14 MR. SEDKY:
On low power.
15 BY MR. ROLFE (Resuming) 16 0
On low power.
17 A
We have gathered together your application.
18 We hav e received and analyzed cr begun to analyze your 19 Tr ack II testimony, LILCO's Track II testimony.
We are 20 monito ring, obviously, the Track II case before the New 21 York P ublic Service Commission.
We have had meetings 22 with counsel to begin discussing economic issues,
' ALDERSoN REPORTING CCMPANY.INC. -
Madan dep.
80 1
how it was treated in this rate case, as to whether 2
th e se in f act are amounts of an ongoing nature that ha v e 3
been included in rates, haven' t been included in rates.
4 And th ose would be the kinds of considera tions.
5 As far as the AFC goes, there is no questica 6
in my mind that that is a wash, that that is a pure 7
wash, that that is pure interest being ca pitalized and 8
amortized over a different period of time and you can l
9 change the numbers twenty different ways, but th e to pre sen t value will still be the same.
11 It is the other much smaller piece, the $10-12 to $20 million, in that range, that we have to look at 13 to determine whether that is the real number or not.
14 O
When you were describing for me~before the 15 issues you intend to 1cok a t, the first was the everall 16 expcsu re of the low power licen'se process in dollarv and 17 cen ts, depending on ultimate resolution of Shoreham.
18 What e vents would you be analyzing incident to that 19 issue?
20 A
I think quite simply it is at least in itia lly.
21 a ques tion we would focus largely on the exposure.
Zt q u e sti o n, treating the benefits as the issues you just ALDER $oN REPORTING COMPANY,INC. ~
Madan dep.
81 1
discus sed right now of what the cost, incremental cest, 2
of decontamination would be in th e process.
3 If you load fuel and once you do that what 4
have you in f act been exposed to, obviously there are 5
increm ental security costs and operating costs of that 6
na ture," and the big cne appears to us at this p' int to o
7 be the decontamination cost if the plant becomes 8
irradia ted because it is producing low power at 5 9
pe rcen t, it's still irradiating the plant and to incretentally what does it do.
11 Have you aff ected salvage?
Was there 12 something you could have salvaged that you canno t now 13 salvag e ?
It would be those kinds of things.
14
'O Have you reached any opinions on that issue 15 yet?
16 A
No.
17 0
Do you intend to draw on the previous work yo u 18 did - be f ore the !arburger Commission in reaching an 19 opinio n on that issue?
. in the 20 A
I'm not sure there is a whole lot 21 Marburger Commission werk.
There is sc=e material there
-n on -decommissioning and decontamination.-
We are'.lo cking
' ALDERSoN REPORTING COMPANY,INC.
F-h
4 Madan dep.
99 1
MR. SEDKY:
I can tell you the answer is nc.
2 I'm no t sure why you want to go through this.
If you 3
would like, off the record I'd be happy to discuss with 4
you which were and which were not and why we wan t the 5
inf orm a tion, which might be a lot faster.
If there's s 6
point to made that this witness dcesn ' t know why a 7
partirular req 0est was made, I don 't know what the poin t 8
is.
I am just trying to nove it along.
9 But if you want assistance in trying to 10 unders tand _ what it is we want and why we want it, I will 11 be hap py to either talk to you about it or write tc you 12 about it s,upplementally.
13 MR. ROLFE:
I would prefer to ask the 14 wi tne s s.
15 BY MR. ROLFE (Resuming) 16 0
Are periodic financial re ports such as I 17
_descri bed a mom ent ago important for:the' analysis that 18 you will be performing ?
19 A
They might be.
m Q
In what respect?
21 A
Again, i don 't know.
I think in the general 22 respec t 1 coking at the general cash situation and the ALDER $oN REPORT'NG CcMPANY,INC.
Madan dep.
,100
~
1 financial situation of LILCC over time, and looking at 2
the tone of events that could happen over this '83 '84 3
time p eriod to us is f sirly critical in terms of what 4
happen s.
5 The payments to Nine Mile were suspended.
The 6
divide nds stopped, all ve ry significan t events.
And I 7
think at least from a financial viewpoint the history 8
lea din g up to today is crucial and the evaluation cf th e 9
reports in terms of explanations, footnotes or whatever 10 they c onsider may point up areas we would want to thin k 11 about.
12 3
With respect to the cost-benefit analysis?
13 A
With respect to the cr.st-benefit analysis, 14 with r espect to the potential issue of how the position 15 of cas h may change, what the operations look like en a 16 month-to-month basis, as.to wha t pe rha ps was projected 17 agains t what actually happened to show th a t there would 18 be variations in those kinds of things.
19 2
. And t hey would be pertinent to what, LILCO 's 20 financial ability to operate the plant?
21 A
Sure.
22 2
Anything else?
- ALDERSoN REPORTING COMPANY,INC.
Madan dep.
109 1
you identified them as being areas which other people 2
would find to be critical te safety, then you have a 3
related issue.
But we will not be able to tell whethar 4
tha t particular cu tback in that particular area may er 5
may no t be able to tell whe the r tha t in a safety-related 6
item.
We probably would not.
I am not a nuclear 7
en gin e e r.
8 BY HR. ROLFE.
(Resuming) 9 Q
I'm only talking about your analysis and ycur 10 investigation in characterizing those three broad.aress.
1 l
11 A
Our investigation is to attempt to find what 12 areas these are and what ca tegories they come under.
We 13 will p ress, as we have in_our interrogatories, in 14 depositions or whatever means we can, to find out what 15 happens in-that scenario.
That is one of our intents.
16 Clearly, you cannet' take the second step if 17 you don't take the first.
So this is a very crucial 18 step in -terms of our investigating what happens in that 19 sce na r io.
where will the cutbacks be, where will they 20 come f rem, and identify those.
21 0
The purpose of that is to determine whether 22 there is any safety problem arising from the company's ALDEASoN REPORTING COMPANY,1Nc.
Madan dep.,$1o 1
fina'ncial condition.
2 A
One of the objectives is that.
3 Q
What is the cther cb jective?
4 A
What is the other?' I thin'k we went through 4
1 5
that this morning as well.
Whether anybody in a j
i 6
decisi onm aking capacity would recommend or would think 7
it sane to go forward with a procedure that has i
i 8
absolu tely no slack.
It's a situation where when 1
9 somebo dy is flat out, it makes sense to question whether l
10 this is the propor environment-under which this kind of i
i 11 an action should take place.
12 2
That goes to the prudency of whether testing 13 ought to be begun.
14 A
That goes to many issues, and one of the 15 questiens' is whether testing ought to be begun, what are 16 the itkely consequences, what are the scenarios, have 17 they a ven been thought through, are there contingency 18 plans.
I believe thcse are all relevant to this 19 pa r tic ular a pplica tion.
20 3R. SEDKY:
I assume you're not asking the 21 witnes s for a ruling on legal evidentiary - issues here.
22 We may - have our own reasons separate frem'his as te why ALDERSON REPORTING COMPANY,1NC.
Madan dep..123 1
A If it 's your understanding one was subsumed in 2
the ot her, I guess we may be comfortable with then being 3
identified sepa rately.
4 3
That's fine.
It makes no difference.
5 A
Fine.
6 Q
My question, then, is whether there are --
7 whethe r the information tha t has been requested in the 8
second discovery request to LILCO in this proceeding 9
relates to any other areas of inquiry other than those 10 you ju st listed for me.
l 1
11 MR. S EDKY:. And those he discussed this 12 m o r nin g.
I mean I don't kncw how you can have it b c th 13 ways.
He said he couldn 't remember everything he 14 testified to this morning.
15 (Pause.)
16 MR. ROLFE:
Let him answer my question.
17-THE 'dITNESS4 I think, to'be as responsive as 18 I can, these issues go to everything we intend to 19 respon d to.
The two areas cf what we're going.to-20 respond to is the list I just gave you, the areas of 21 your e xamination this; morning.
22
.I would only add'to that that it is not at all ALDERSON REPORTING COMPANY,INC.
m.
i
\\
Madan dep.124 1
unusual, and we in tend to make every e f fo rt to 2
scrutinire these documents to see whether it gives rise 3
to fur ther evaluations.
We have asked for a lot of 4
correspondence between officers of the company, which we 5
thinx is relevant.
Th ey may, in fact, give rise to 6
f ur the r uncertainties..
It may be a cash-related issue.
7 I t may not be.
But if something is contained within 8
these documents that relate to the uncertainty of the 9
process and relate to the three broad issues we spoke to about -- economic, financial or public interest -- we 11 in tend to raise them.
12 Is there a pcssibility that there is 13 co rres pondence within the ccmpany indicating certain 14 d ra wb a ck s, safety related, financial related?
I don't 15 know.
Is there documentatien within the company that 16 indica tes that the low power licensing is so critical to 17 its financial attractiveness that it ough t to be p re sse d 18 ah e ad regardless of any other f act?
I don't-know what 19 this is going to say, but we intend to get these 3) d ocume n ts, examine 1them and'see if any ancillary related 21 issues. come up.
I think you would expect us to raise 22 them, and we.would.
~
' ALDERSoN REPORTING COMPANY,1NC..
43 Bakshi deposition 1
A I have not f erned any conclusions v.hether they
{
2 are suitable or are no t suitable.
And as I said, I may 3
not have related the two also.
I have been reading 4
generally documents or literature regarding them, and I 5
may not have come to any particular conclusion tha t th e y 6
are re ally suitable for the purpose for which they are 7
in t end ed.
8 2
When do you intend to reach those conclusions, 9
or do ycu?
10 A
I definitely do.
If I'm asked to testif y, I 11 will come to some sort of conclusion.
As you realize, 12 one ha s to do a good study of any particular engine.
13 There are a lot of components in a diesel engine.
One 14 has to relate to different experiences, as you 15 m en tio n e d, you know, in the industry to see how it's 16 been f unctioning in other f acilities, have they been 17 used f or such purposes elsewhere, have they been used 18 for a nuclear f acility elsewhere.
You know, one has to 19 consid er a lot of' things before one can say yes, this 20 engin e meets the criteria for what it is intended.
And L
21 I have nct really gone to any depth of that. sort.
22 0
I take it that you have not doae tha t t
ALDERSoN REPormMG COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.C. 20001 (200 628 9300
Bakshi deposition 63 1
0 Is there anything else you intend te do?
f
(
2 A
I think that would be the major thrust o f th e 3
work.
I can't offhand think of anything else.
4 Q
As of today have you reached any conclusions 5
or formed any opinions with respect to the EMD diesels 6
at Shoreham or the method in which LILCO intends to use 7
th e m?
8 A
I have not reached any conclusion.
I may 9
have, if I can use the word " concerns," about the 10 ce r tai n wa y I saw things were up there when I was at the 11 site.
But again, as I said, I would not reach any 12 conclu sicas without going into the drawings, the 13 docume nts which I have already requested.
14 2.
Tell me what those concerns are.
15 MR. ROLFE Let's take a five-minute break.
16 (Recess.)
17 MR. LANPHER:
Can you repeat the question?
18 BY MR. ROLFE:
(Resuming) 19 0
Mr. Bakshi, let me repeat the question that I 20 posed before we took the break.
21 Ycu advised that you had some preliminary 22 concerns as a result of your site visit.
Can you list
(
ALOER8oN REPORTING COMPANY,INC.
20 F ST N.W., WASHINGTON. D.C. 20001 (202) 828 9000
l Bakshi deposition 173 j
1 A
Could be industrial standards, international
{
2 reg ula tions for diesel engines.
Yes, I am aware of 3
reg ula tions.
4 0
Putting aside the NRC's regulations governing 5
onsit a power sources for a minute, are there any codes 6
or sta ndards applicable to the EMD generators at 7
Shoreham with which these diesel generators do not 8
com ply ?
9 MR. LANPHER:
Can I have that question read 10 back o r repeated?
11 MR. ROLFE:
I will try to repeat it myself if 12 you want.
(
13 MR. LANPHER.
Either way.
14 MR. ROLFEt I will do that and save her the 15 tro ubl e.
16 HR. LANPHER:
You had said leaving aside.
17 BY MR. ROLFE:
(Resuming),
18 3
Leaving aside for a minute the NBC's 19 reg ula tion s, are there any other codes cr standards 20 applicable to the EMD diesels at Shoreham with which 21 they de not comply?
22 A
I do not know.
'b j
ALDERSON REPORTING COMPANY. INC.
N F ST, N.W, WASHINGTON, D.C. 31001904 83-8100
Bakshi deposition 170 1
0 Do you know what the industrywide experience 2
has been with respect to reliability of diesel
{
3 genera tors used ' at nuclear power plants?
4 A
At nuclear power plants is only what I have 5
gained experience through dealing with Suff olk County 6
and what I have read generally.
7 0
Have you read or are you aware of any figure 8
concer ning the availability or reliability of those 9
machines?
10 A
I don't recollect any figure offhand.
11 0
Near the beginning of your deposition you gave 12 me a list of ma tters that you would want to consider, I 13 guess, in looking into the reliability of these diesels, 14 any diesels.
One of them, for example, was its ability
~
15 to reach speed.
Do you have any opinions with respect 16 to the ability of these E*D diesels to reach their 17 required speed ?
18 A
I have no opinions as yet.
19 0
Do you intend to make-any investigation with 20 respect to their ability to do that?
21 A
I probably will'oc through mest of the lists 22 which I gave you.
I have not attempted it yet to do any L
ALDGWoM REPORTING COMPANY,INC.
30 F ST., N.W, WASHINGTON, D.C. 20001 QOQ 8&e3OO
A Bakshi deposition 176 i
indici ted about the past.
(
2 0
How f ast do these :nachines need to reach thei r 3
speed ?
4 A
I don't know.
5 0
How will you find that out?
6 A
By asking what I've asked in the discovery, or 7
if I h aven 't, I probably will ask what the -- what t hes e 8
were originally designed for, go through all the design 9
criteria when they were initially manufactured.
These 10 generators seem to have a lot of place s mentioned.
Th e y 11 have b een repowered and rebuilt.
I'd like to see all 12 those documents, why they were repowered, why they were
~
13 reb ull t, and see whether they' ve had any incr easin g in 14 ra ting,.an d why, and what are the reasons.
I'd like to 15 see all that before I can make any decision.
16 Q
Do you intend to undertake any investigation 17 with respect to the ability of these machines to rea ch 18 s pe ed other than through a review of the documents which 19 LI1CO will prod uce ?
20 A
I'm-not aware of any richt now.
21 0
Do you have any opinion with respect to the t
l 22 abilit y of these f our EMD diesels at Shoreham to t ak e
{
i l
ALDERSON REPORTING COedPANY,INC.
20 F ST, N.W, WASNINGTON,0.o. 20001000 MSIO0
Bakshi deposition 177 s
1 load?
2 A
I have no opinion.
{
3 Q
Do you intend to investigate that factor?
4 A
As I said, I will investigate all thwse 5
f actors, and without going through each one, what steps 6
exactly I will take would be just speculation.
I would 7
not know what I would be exactly doing, but I generally 8
would draw up a list when I start that process, or with 9
Mr. Eley, confer with him and say these are the facters to w e ' re going to look at.
We may not even 1cok at all the 11 f a c to r s.
We may 1cck at some cf the f actors, depending i
12 again on the time, a s I sai d, and then fo rmulate a plan,
C 13 this is what ' we're going to do, do we need anything 14 else, and things of that na ture.
15 2
But you have not formulated that plan now?
16 A
No.
17 0
Other than the time available to you, how will 18 you ma ke distinctions among these various factors that 19 you listed for me as tc which ycu wculd investigate and 20 w hich you might not?
21 A
There's maybe some that are more important 22 than o the :s from opera ting experience.
I would go abou t
(.
1 l
ALDERSON REPORTING COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.c 20001 (202) 828-9300
Bakshi deposition 17e 1
d oing that and leave the rest if I dcn't have time.
(
2 0
Which of these might be mora important than 3
o th ers ?
4 A
I don 't recall what order they are.
You know, 5
five, six, seven items of the ten items that I ref erred 6
to.
7 O
Let me go back to that question, then; tha t 8
is, wh a t types of investigation might ycu undertake to 9
determine the ability of these machines to take load ?
10 A
Review the operating history.
11 Q
Anything oth er than review of.the operating 12 his tor y ?
13 A
Nothing at this peint.
14 0
Have you undertaken -- strik e that.
15 Have you reached any conclusions or opiniens 16 with respect to th e reliability of any of the components 17 of the EMD diesels at Shoreham?
18 A
None whatsoever.
19 0
Do you intend to' investigate tha t f actor?
20 A
Hight.
21 Q
If you do, what sort of investigation will yo u 22 u nd er t a ke?
(.
1 ALDERBON REPORTING COMPANY,INC.
20 F ST, N.W. WASHING TON, D.C. 20001 (201Q 820 9l100
Bakshi deposition 181 h
1 Q
That's just speculation on your part?
j(
2 A
It's not speculation.
I know a lot I ca n giv e 3
you names of theo, but I don't know the exact amount --
4 does this firm do it, does he do it or not.
But 5
g e nera lly, yes.
6 0
Do you have any opinion as to whether these 7
diesels at Shoreham, the EME diesels, are, I believe 8
your words were saf e enough for what they were intended 9
to be used for?
10 A
No.
11 0
You don' t knew?
12 A
No, I don't.
I haven't formulated any o pinio n.
13 0
What will you need, if anything, to formulate 14 an cpinion about that?
13 A
It includes all the concerns, plus the f actors 16 that I mentioned there.
17 0
How will you do that, though?
18 A
After I have considered all of these, if it 19 m ee ts these requirements, then I.will say yes, it is 20 saf e, ' rela tively.
21 0
When you say meets thtse requirements, are you 22 ref erring to requirements.that you have imposed ~in - yeur C
4 ALDER 8oM REPORTING COMPANY.INC.
20 F ST, N.W. WASHINGTON. D.C.20001904 825 9300
Bakshi deposition 182 1
in v est igatio n, or are you referring to any objective se t
(
2 of req uirem ents?
3 A
The six requirements which I mentioned.
4 0
The six concerns?
5 A
The six concerns primarily, plus these other 6
f a ctor s.
Go through the design components and this 7
other one you talked about.
8 0
One of the other things you mentioned earlier 9
was th e lube oil capacity, I believe, and if I'm wrong, 10 correc t me.
Is th at anything different?
11 A
That's s concern.
12 0
Lube oil censumption we were discussino?
13 A
Yes.
14 3
Do you have any opinion as to whether the 15 stress levels on the f cur EMD diesels at Shoreham pese 16 any problem?
17 A
Stress levels on what?
18 0
On any components in the machines.
19 A
I haven't done any design calculations.
I 20 don't kncv.
21 Q
Do you intend to do any design calcula tions?
22 A
I don 't know.
If I have the time, I may or j
k.
i ALDERSON fW.POrmHG COMPANY,INC.
20 F ST, N.W WASHINGTON, D.Q 20001 G108 828-9300.
i W
Bakshi deposition 187 1
manuf seturers in America purport to comply with ABS or
{
2 Lloyd's standards for their stationary diesels?
3 A
I have not studied that in depth.
4 0
So you don 's know?
5 A
Not offhand.
6 0
Are you familiar with the surveillance tes tin g 7
prcrosed by IILCG for these EP.Cs at Shorehan?
8 A
No.
9 Q
Do you have any opinion as to the frequency 10 with which surveillance testing ought te be undertaken 11 to ensure some indication of reliability?
12 A
Some indication of reliability?
(
13 0
Satisfactory ind'ication of reliability.
14 A
Not yet.
15 0
Well, how will you arrive at that if you dcn't 16 have iny opinica now?
17 A
Well, if it meets all the objectives 4hich I 18 have set out fo r it, I will see what the engine 19 manuf acturer says, what scheduled maintenance must be 20 done, and frem that I maybe will compile a list of what 21 could further be done to enhance the reliability of she 22 e ng in e s.
((
ALDERSoit REPORnNGCoMPANY,INC.
- 20 F ST, N.W, WASNINGTON, D.C. 20001 (204 828-9300
Bakshi deposition 193 1
logs.
I need to read more in order to determine.
2 0
Based on what you have read to date, do ycu 3
have s ny opinion as to the reliability of the machines 4'
based on their operating history?
5 A
What?
6 Q
Based on what you have reviewed to dat e, do 7
you ha ve any opinion as to the reliabilit y of these fou r.
8 EMD diesels based on their operating history?
9 A
Based on what I have. read until today, t h e re ' s 10
.a n ee d to know more, and I've not f ormula ted an opinion.
11 Q
You mentioned earlier that how the diesels are 12 ho used may be a factor in-ycur evaluation of their 13 reliab lity, is that right?
14 A
To a certain extent, yes.
15 Q
Can you explain that to me, how they would 18 affect your opinion?
17 A
Well, it's the same thing basically.
The way 18 the TDIs are housed, you would have fixed engines rather up than, you kncv -- you would have a' better scurce of fuel 20 oil, better firefighting f acilities.
All the concerns
.21 which ycu have mentioned, the majority cf them would be 22 includ ed, plus the re may be better means of overhauling
(.
L ALDER 8oN REPORTING COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.C.,20001 (204 828 9300
Bakshi deposition 198 1
A Components and things like that, yes, but not 2
structural if you call it a construction of things, no.
(
3 0
Do you intend to express any opinion with 4
r es pe r t to the capability of the GM EMD diesels at 5
Shoreh am to power the necessary emergency loads to 6
mitiga te any accident which might be encountered during 7
low power testing?
8 A
Once again.
9 2
Do you intend to express any opinion with 10 respec t to the capability of these EY.D diesels?
And by 11 capability I mean to distinguish that from the 12 reliab ility of the machines in operation, but wh ethe r, 13 assuming that the machines are reliable and will operate 14 as they.are intended, whether they are capable of 15 powering the emergency loads that might be necessary to 16 mitigs te an accident a t Shoreham.
17 A
I don't know.
18 MR. LANPHER4 I belatedly will object to the 19 question because I still don't understand it.
It was 20 vqry confusing.
21' MR. ROLFE:
I think he did.
22 MR. LANPHER4 I don't understand wha t you mea n L
ALDERSON REPORTING COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.C. 20001 (200 628 9300
Eley deposition 33 A
1 f orme d any opinions or conclusions with respect tc the
{
reliability of the END diesels at Shoreham or a 2
3 contrarison of those diesels with a qualified nuclear 4
diesel ?
5 A
As I have said before, we have not been able 6
to get all of the data that we need in order to make 7
that comparisen.
So ne, we have not made any formal 8
conclu sions on tha t at this stage.
8 3
Tell me, if you will, what additional work you 10 in tend tc de in your investigation?
11 A
I think Mr. Bakshi in his deposition has 12 really covered every area that we are going te look at 13 that I can recollect also.
There is some termino 1cgy 14 that is used that we need some definition on as well, 15 that we are a little unsure of, that we would like te --
16 we have a couple of other discovery requests with rega r d 17 to tha t.
18 Q
Can you tell me what terminology it is that 18 you are having difficulty with?
20 A
Cne of them is "repower".- It is not a term we 21 use in the U.K., so I would like that defined a little 2(
cleare r.
I'm not sure whether that means a major
(
. ALDERSON REPORTING COMPANY,INC.
20 # ST., N.W WASHINGTON. D.C. 20001 (204 828 9300 t _.
l Eley deposition 42 1
must n ot only consider the una vaila bility ; you m us t
(
2 consider that in conjunction with an effective ru n ni ng 3
period.
4 0
Well, let's get tc that.
Do you have any 5
opinio n, ba sed on the maintenance or operating records 6
that y ou have seen, concerning the running reliability of the se machines?
8 A
No, I have not.
~
9 0
You heard Er. Bakshi refer to some roughly 10 calcula ted percentages of these units' unavailability in 11 the pa st?
12 A
Yes.
e 13 0
Do you scree with me that it 'is important to 14 dif fer entiate between unavailability due to a planned 15 o utage for maintenance, for example, and unavailability 16 due to mechanical failures or breakdowns or the like?
17 A
Yes, I a gr.ee, there 's a diff erence.
18 Q
Have you seen any records reflecting the 19 unavailability of these machines due to mechanical 20 f ailures -or breakdowns ?
21 A
There are some documents to that effect, but 2{
.with~ regard to the actual figurer. on availability I L
ALDERSON REPORTING COMPANY,INC.
20 F ST, N.W. WASHINGTON, D.C. 20001 (200 828 9300
Eley deposition 43
~
1 don 't recollect them offhand.
{
2 0
Ycu don'+ have any opinions on that?
3 A
I don 't have any opinions on that right now.
4 Q
When we started dcun this track I had 5
originally asked you whether there was any accepted 6
standa rd i the industry for judging the reliability of 7
diesel gen e ra to rs, and I don't believe you ever answered 8
the qu estion.
Is there?
9 A
Standard on reliability There may be, but 10 I.m no t aware of it.
11 MR. ROLFEt Let's take a ten-minute break.
12 (Bece ss. )
13 BY ME. ROLFEs (Resuming) 14 0 -
Mr. Eley, do you have any expertise in the 15 area o f seismology?
16 A
No.
17 3
Do you intend to do any work or express any 18 opinio ns with respect to the-ability of these EMD 19 diesels to withstand a seismic event?
20 A
No, I do not.
31 0
Do you intend to perform any investigaticn or express any opinion with respect to the operating 2{.
(-
i L
fI ALDERSON REPORTING COMPANY,INC.
l 2j F, N.W, WASHINGTON, D.C. 20001 (202) 828-9300
i 55 Eley deposition
{
1 1
that or not?
1
(
2 A
Well, it may not be performed by me.
I'm 3'
quite sure it will be performed by Mr. Minor.
4 0
Do you intend to review all of the additional 5
documents that are being produced or that will or may be 6
produced by LILCO in this proceeding, or do you intend 7
to rely on Mr. Bakshi's review of those documents?
8 MR. LANPHER:
You mean all the diesel-related 8
ones?
10 MR. ROLFE:
Yes, I'm sorry.
11 THE WITNESS:
I intend to review some of those 12 do cum e n ts.
Mr. Bakshi will do some independent review
~
13 of some documents.
And there is a possibility that we 14 may extend the people that are being utilized on this 15 case because of the timing involved.
16 With regard to your quastion of whether I will 17 review all of the documents, I would say possibly not, 18 becaus e I am concentra ting on some TDI work, as you 19 know.
20 BY MR. ROLFEs (Resuming) 21 Q
Have you performed any work to da te or^ reached 2{
any conclusions with ~ respect' to the ability of the EMD ALoaR8oM REPORDNQ COMPANY,INC..
me F ST., N.W, WASHINGTON, D.C. 20001 (20lD GE$300.
m Eley deposition 56 l
1 diesels to reach the necessary speed?
l
(
2 A
I have not performed any of those 3
calculations, no.
4 0
Do you know what you intend to do with respect 5
to rea chin g any conclusions on that subject?
6 A
I do believe there's a specific requirement 7
for engines within the nuclear industry to reach the 8
rated speed at under ten seccnds.
There is a 9
possibility that we will look at that issue.
Yes, it 's to a pcss ibility.
11 0
Do you know why that's a requirement for 12 nuclea r diesels?
13 A
I'do not.
14 0 -
Do you know, for a plant operating a t f ull 15 power, how quickly it is necessary to have AC power in 16 the ev ent of a 10C A, for example?"
17 A
I do not.
18 Q
Do you have any knowledge as to whether it is 19 necessary in a plant operating at five percent power fo r 20 a diesel generator to reach its rated speed within ten 21 second s ?
y A
Would you repeat that question?
L ALDERSON REPORDNG COMPANY.lNC.
20 F ST N.W., WASHINGTON. D.C. 20001 (202l 825 9000
Eley deposition 58 1
A The only limitations I have read of is, I
(
2 believe it was if my memory serves me correctly, a 3
reccam endation by the engine builder that the engine 4
s hould not be run under a specific power rating.
The 5
reasons for this, I don't k now why.
6
-Q Do you have any have you done any 7
investigstion with respect to its ability to pick up th e 8
load that it will see in the event of an emergency?
And 8
by "l u " I mean the EMD diesels at Shoreham.
to A
I have net dcne that yet, no.
11 0
Do you intend to do that?
12 A
This I think would be possibly more in Mr.
13 Mincr's area.
1#
0 Meaning you do not intend to investigate that 15 area?
16 A
It would not b'e one of my priorities, no.
I 17 assume you mean the response f rom the generator with 18 regard to picking up that 1 Cad; is that correct?
19 2
Yes.
20 Do you have an opinions with respect to the 21 reliability of any particular componen ts of the EMD 2(
diesels at Shoreham?
- l l
ALDER 8oM REPORDNG COMPANY,INC.
20 F ST., N.W., WASHINGTON, D.C. 20001 (200 628 9300
9 Eley deposition 59 1
A Not at this stage.
(
2 2
Do you intend to conduct any investicatien 3
inte that subject?
4 A
I believe Mr. Bakshi mentioned the problem 5
area he felt with regard to the turbocharger drive 6
arr an g emen t s.
We do not knew what they are.
We ' d lik e 7
to have a look at those, so it will be necessary for us 8
to get some blu eprin ts, which we've asked for in our 9
lat est discovery.
And that is one of the areas we will 10 be looking at, yes.
11 Q
Other than the tu rbocha rger, are there any 12 other components which you will specifically be 13 investigating on the E?.D diesels at Shoreham?
14 A
I do' believe there has been some cylinder 15 heads cracking and tha t's probably another component 18 that we will look at.
There's a lot of references in 17 the documents that we have already read with regard to 18 rust in the cylinder liners, so this is an area that we 19 will look at.
20 I don't recollect of f hand whether there were 21 any ot her components that were being considered at this 2{
time.. That's not to say that, given more documents and 1
f N REPORTING COMPANY,INC.
gp
.W., WASH 4NGToN, 0.C. 20001 (202) t28-9300
Eley deposition 63 1
Q Have you reached any opinions with respect to
{
the ba ttery sta rting unit at Shoreham en the erd's?
2 3
A I have not reached any opinions on that at 4
all, n o.
5 0
Is anyone else at Ocean Fleets currently 6
wor kin g on the Shoreham project besides you and Mr.
7 Bakshi ?
8 A
There is not at the moment, but there is a 8
possibility that I might change that in the near 10 future.
11 0
Do you know now who you might enlist?
12 A
I do not, but I am seeking additional 13 assistance in this matter.
14 Q
We spoke a few minutes ago about the necessit y 15 in you r opinion for looking at the running reliability 16 of diesels in addition to their starting reliability in 17 order to reach an overall reliability judgment..
18 A
Yes.
19 0
Is it as impcrtant to know about the running 20 reliab ility if the machine is only required to run at 21 most f or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a clip?
2{
A I think so, yes.
n t
t ALDUISoN REPORTING COMPANY.!NC.
20 P ST, N.W, WASHINGTON, D.C. 20001 (200 628-9300
o 36 Meyer deposition C
1 calls didn 't de al with the substance of the analysis?
(
2 A
That is correct.
3 0
And dealt with the arrangenents f or perf eriting 4
the wo rk?
5 A
That is correct.
6 0
Doctor, throughout the deposition I am gcing 7
to be asking a number of questions about the analysis.
8 To the extent that particular portions of the work are 9
being performed by Dr. Roesset, I would a ppreciate it if 10 you would indicate that he is perf orming those 11 partic ular portion s of the analysis.
I think that will 12 save going back through the whole set of questions
{
13 twice, asking vhat you are doing and asking what he is 14 d oing.
15 A
But as I indicated, we haven't even' decided 16 yet wh at exactly we will perform, so therefore I don't
~
17 know yet what I will do and what he will do.
1a Q
Fine.
19 Now, in your initial phone-conversation with 20 Mr. Hu bbard on April 9, what did he ask you to do?
21 A
Basically asked.if I were available to perfor m 22 this type of seismic analysis of various structures or
(
ALLEH0oN REPORTING COMPANY,INC.
So F $7 N.W WASHINGTON. DA 20001 (2029 828 9300
Meyer deposition 62 1
are ge tting this f eeling for components?
{
2 A.
Well, actually, the physical components 3
themselves, be it buildings or components or 4
structures.
5
, O Sc just to see what yea were dealing with?
8 A
Ye s, exac tly.
7 0
As a result of th at visit, did you reach any 8
conclusions or form any opinions?
9-A No final opinions.
10 0
Did you have any preliminary impressions cr 11 conclu sion s tha t. ou reached?
12 A
Hy preliminary opinions or impressions were 13 that some of the equipment that we did visit has been 14 put up more for temporary purposes, and I did n,ot get 15 the im pression as if it had been engineered f'dr seismic 18 reliab le behavior.
17 Q
Do you re all what equipment that was?
18 A
As an example, the control panel cubicle for 19 the EM D generators, it was just placed on temporary 20 timber, and no engineer would design - semething like tha 21 for pa rmanent use.
22 2
Okay.
/(
l ALoensow nsponnNG COMPANY,1NC.
20 F ST., N.W WASNINGToN D.C. 20001 (200 828-9300
Meyer deposition 77 C
1 what the strecces and deformations due to seismic loads
(,
2 will d o to the operational characteristics cf an 3
electr ical syst em.
4 0
Have you cr do you intend to develop a lis t o f 5
the ma jor electrical components for the EMD. diesels?
6 A
I will be looking.only into the diesel 7-genera tor itself, whether it will be -- whether the fuel 8
line sight have a probability of rupturing during an 9
earthquake, or if the contrci b./.1 ding might slide cff 10 its foundation.
This is the type of question I will 11 answer, and I will not go into any electrical aspects, 12 mechanical aspects of the equipment.
~
13 2
In your proposal in Phase 2, you indicated 14 four g eneral areas that you would be 1ccking at,,
A, B, 15 C, and D, and we eliminated B, or part of B, he 16 Holtsv111e gas turbines.
17 Starting with A, on-site power source is con sis ting of a gas turbine, transformers, the switch 19 yard, an the four mobile diesel generators and their 20 inter:onnecting parts, have you reached any conclusiens 21 or cpinions with respect to any of those piecas of 22 equipm ent?
t ALDERSON MEPoRTING COMPANY,INC.
20 F ST, N.W, WA$HINGTON, D.C.20001 (M $20-9300
Meyer deposition 78
(
1 A
No, not yet.
(
2 Q
Have you reached any preliminary opinions er 3
conclu sions -- and that is other than the ones you have 4
told 3e about -- that you have reached as part of ycur 5
site visit?
6 A
No, not yet.
7 MR. LANPHER:
Can I get a clarification?
He 8
also prior to the break described things that as a 4
9 result of his visit he decided he wanted to look at 10 f u r th e r.
That is not a conclusion or an opinion except 11 in the sense that he identified things that he wanted tc 12 look a t.
(
13 I just want the record to be clear that to 14 that extent he made some judgments, at least.
15 MR. EARLEY:
Well, he said he had s'"me o
16 im p res sicn s.
17 BY MR. EARLEY:
(Resuming) 18 0
And beyond those impressions,'from the site 19 v isit, you don't have any other conclusions, impressions i
20 or concerns?
21 A
No.
22 Q
With respect to the transmission line systems kc i
k ALDERSoN REPORTING COMPANY,thC.
30 F ST., N.W., WASHINGTON, D.C. 20001 (20l0 828 9300
Meyer deposition 79 e
k 1
connec ting the on-site equipment to the local
(
2 sub sta tions, do you have any opinions, impressions or 3
concerns that you have iden tified other than those t hat 4
you' 11sted as a re sult of your site visit?
5 A
I have no opinions at this point yet.
6 Q
No prelimina ry j udgments?
7 A
No preliminary judgments, no.
8 Q
With respect to substation components used to 9
switch or control incoming powe r to the site, have ycu 10 reache d any opinions, final or preliminary, or 11 impressions or concerns with respect to those items?
r 12 A
No, I have not.
(
13 0
You also indicated that your work would ccver 14 suppor ti ng equipment, and you list f uel oil sto. rage tanks for the diesels and turbines as an examp"le.
15 16 What other supporting equipment besides the 17 f uel oil storage tanks will you look at?
18 A
I don 't recall what rou had named these 19 variou s pieces.
We have taken pictures of some of th 20 physical links between the various electrical 21 compon entr, and I would be able to identif y them on the 22 pic tu r e s.
I don't remember the names.
But basically w e L
<v ALDERSON REPORTING COMPANY,INC.
20 F ST., N.W., WASHINGTON, n.C. 20001 (202) 628 9300
r i
j i
Meyer deposition 80 C
1 are talking about tran sformers, circuit breakers, maybe
(
2 some t ransmission towers.
3 0
So under supporting equipment, you will lock 4
at the physical links which you describe as electrical 5
physical connections.
6 A
Correct.
7 2
And the fuel oil storage tanks.
8 A
And the pipelines, yes.
9 Q
The fuel pipelines?
10 A
Yes, from the tank tc the diesels.
11 Q
Would anything else be covered by the ca tegory 12 of sup porting equipmen t?
13 A
Pardon me?
14 3
Would anything else be covered under this 15 design ation supporting equipment?
16 A
I cannct recall offhand.
I don't think so.
17 That pretty much describes all of the equipment.
1s 0
With respect to the fuel oil storage tanks, 1g have you reached any preliminary or final conclusions 20 aboit any concerns you can identify?
21 A
No.
22 Q
And with respect to the physical electrical
(
ALDER 8oN MPORflNG COMPANY,INC.
20 F ST., N.W WASNINGTON. D.C. 20001 (202 428 9300 m~
Meyer deposition 81 1
con'ne:tions tha t you have just referred to, have you j
2 reached any preliminary final opinions, conclusions, or 3
have any concerns in that area ?
4 A
No, I have not.
5 0
you indicate that your analyses will consider 6
the ef fects of the SSE on the ability of the equipment 7
to function.
8 Co uld yo u de scribe f er me how you will assess 4
9 the ability of the equipment to function as a result of 10 the SSE?
11 A
I will give you a very simple example.
If a 12 transf ormer is found to topple over as a result of an 13 earthq uake, I will say it will not'he very difficult to 14 show that it cannot perform its intended functions.
15 This is a crass example.
16 More subtle examples,'there may be certain i
17 displa cements o.c vibrational characteristics that can '
18 have electrica.1 consequences, and in order to assess the 19 relia b ilit y, I will need the expertise of an electrical 20 engine er to interpret the consequences cf - certain 21 re s pon ses.
22 Q
And have you identified an electrical engineer
.- (
t-ALDERSON REPORTING COMPANY,INC.
30 F ST, N.W. WASHINGTON, D.C. 20001 (202) 038-9300
Meyer deposition 143 1
A By a dynamic analysis.
(
2 Q
And that dynamic analysis requires you te 3
develop a mathematical model of the tower?
4 A
Yes.
5 Q
What other inputs go into the mathematical 6
model?
7 A
I have to kncv the properties of these 8
ins ula to rs.
9 0
Does that go into the model itself?
10 A
Yes.
11 Q
Or is that used in de te rmining whether the 12 insuls tors will f ail?
13 A
No.
It will be part of the medel.
14 3
Have you performed any part of this analysis 15 yet?
16 A
No, I ha ve net.
17 Q
Can we go to the next item?-
18 A
I believe this is it.
is 3
Doctor, in going thrcuch this list of 20 pictures, and in our previous discussions you have i
21 described for me a number of components that you intend 22 to analyze and the type of analysis ycu that intend to
(.
(_
ALDER 00N REPORTING COMPANY.INC. -
l 20 F ST N.W WASHINGTON. 04'. 20001 (202 820-9000
Meyer deposition t ag 1
perform.
Richt now are you aware of any other
(
2 components or any analysis that you intend to perfors 3
that you have not mentioned here today?
4 A
No.
5 0
With respect to any cf these items cf 6
analys es, I take it that you have not formed any 7
opinions, either preliminary or final?
8 A
No, I have not.
9 2
Have you developed any outline, either in 10 w ri tin g cr in your mind and your thought proctss, 11 concer ning the types of opinions you may present in th e 12 hearings in this case?
13 A
I didn't quite get that q u e r tio n.
14 0
Have you developed, either in writing, or in 15 ycur mind thought th ro ugh the. types of cpinion's er an te outline cf the kinds of opinions you may present at 17 trial in this case?
18 A
I have no opinions yet, so I have not 1g expres sed it either in writing or in my mind yet.
20 0
When do you intend te reach any opinions er 21 judgmants or conclusions with respect to the work you're 22 performing?-
k.
L ALDERSON REPORTING COMPANY,INC.
20 F ST, N.W., WASHINGTON, OA 20001 (202) 828-9300
r Meyer deposition 145 1
A After I have performed these analyses.
(
2 0
You have indicated ycu have not performed any 3
of the se analyses today?
~
4 A
That's correct.
5 0
When do you intend to start performing these 6
analy s es?
7 A
As soon as I get the technical data that we 8
have requested through discovery.
9 0
And have you developed a schedule for 10 performing these analyses fc11owing the receipt cf this 11 inf orm ation ?
12 A
What do ycu mean by schedule?
13 Q
How long do you think it will take to perform 14 these analyses following --
15 A
In my original estimate here we predicted 18 about 24 o ys for phase one and two -- no, phase one is s
17 com ple ted.
So I still stick to approximately 20 man 18 days, both for me and for Dr. Roesset.
That's the test to estima te that I have available richt now.
20 Q
So, in essence, what you're saying here today I
21 is you have not accomplished anything yet in phase two?
22 A
The site visit here is listed as phase two.
i ALoanson naromiNo COMPANY,INC, 30 F ST, M.W, WASHINGTON, D.c. 2000t (202 828 9300
r Weatherwax deposition 85 C
1 3
You mentioned that you would look at how the 2
20 meg awatt gas turbine connected into the bus.
What is 3
the significance of that piece of information for your 4
analys is?
5 A
Various failure medes.
Anything that could 6
affect the' routing cf that.
Any contributions to 7
una vailability.
We would be going from the starting of 8
it throughout the full connection period.
9 0
So you would look at all the components 10 be twe e n the gas turbine and the bus and check th eir 11 reliab ility ?
(
12 A
Or availability, which encompasses maintenance 13 outage as well.
14 Q
And do you now -- Have you done any work yet 15 to det ermine what potential f ailure mechanisms there are 16 in tha t connection?
17 A
No, I have net.
18 0
You also mentioned the underground portion of 19 the line, and you noted that it was near the contrcl 20 b uildin g.
What is the significance of th a t ?
21 A
Nothing particularly.
All we are going to do A
22 is just follow the routing ef-it where it ties inte the m
ALDEfWOM REPONDNG COMPANY,INC.
Weatherwax deposition
.182 h
1 than your review of the reactor safety study?
2 A
No, I did not.
3 0
Now, in your position as a systems safety 4
supervisor at McDonnel Douglas, did you participate er 5
perform a probabilistic risk assessment or other 6
assessment of a commercial nuclear power plant?
7 A
I did not.
8 0
Since you've been president of SERA, or since 9
yo u 've been with SERA Energy Risk A ssessment, you've 10 indica ted you have reviewed some probabilistic risk 11 assessments for commercial nuclear power plants.
Have
(,
12 you be en responsible f or performing a probabilistic ris k 13 a ssess ment for any plant?
14 A
I have not.
15 3
In the course of the. review you have' conducted 16 so far, with respect tc LILCO's application for a lcv 17 pow er license, have you reached any opinions, either 18 final er preliminary, with respect to any aspect of your 19 reviaw?
20 A
I have reached no opinions regarding the 21 drivin g motivation f or the 10 megawatt or the 20.
f 22 megavi tt Jas turbine.
(
j w
l
)
l ALDERSON MEPORDMG COMPANY.lfC e
' 83 1
Weatherwax deposition 1
I have general impressions -- thought that 2
carticularly based on a site visit, that LILCC has not, 3
in my cpinion, dotted all the l's and crossed all the 4
t 's.regarding various areas where the low power 5
configuration could have been made saf er.
6 I also felt, the example about the diesel 7
geners tors on railroad ties, there seemed to be a 8
certain casualness and slap-dash perspective to the 9
whole diesel generator assembly, certainly not something 10 I c an quantify from that.
11 0
Any other general impressions or conclusions
(
12 in any other part of your analysis?
13 A
No.
14 0
Now, with respect to your general impressicn 15 that LILCO has not dotted all the l's and crossed all 16 the t's, can you tell me precisely what you are 17 ref err ing to there?
-18 A
Well, I was thinking in terns of the manner in 19 w hich the four units were operated.
Not ha ving done' th e 20 quantitative analysis, I can't say what the actual 21 results will be, but it strikes me that if you wanted to J
22 genera te a whole string of dependencies and completely
(
ALDERSON REPORTING COMPANY,INC.
m a RT N w. WASHeNGTON. O C. 20001 (208 828-9300
4 El Gassetr deposition 8 1
as tha t documen t is concerned.
(
2 2
Do you know whether they have reacned any 3
conclusive results concerning installing black start gas 4
turbines as a result of the review of any or all 5
docume nts ?
6 A
No.
7 2
Mr. El-Gasseir, have you formed any opinions 8
or rea ched any conclusions with respect to the low p cwe r 9
license application that you are reviewing?
10 A
No.
11 0
Have you been asked to form any opinions er 12 conclu sions ?
{
13 A
No.
14 0
Do you expect to testify as a witness in this 15 proceeding and offer any opinions or. conclusions?
i 16 A
No.
I don 't expect tha t.
That has never been i
17 indicsted to me.
18 RR. EARLEY:
Why don't we take about a 4
19 five-sinute break?
20 (Recess.)
21 BY MR. EARLEYs (Resuming) 4 22 2
We just have one more question.
We can alway s 1
?
ALDERSON REPOMnNG ColdPANY.INC.
20 P ST., N.W., WASHINGTON, D.C. 23001 (30 859300 E. -
Minor deposition 46 1
but I did follow up with them and a ttempt tc deterrine 2
their availability and schedules, to put together a pla n 3
f or what we might dc.
4 0
You said in general MHB was acting as a 5
coordinating consultan t.
Are there any areas in which 6
MHB in tends te develop its own testimony and express 7
opinio ns incident to this low power proceeding?
8 A
There are plans a t this time to have some 9
testim ony sponsored by MHB.
10 0
And what would be the subject of that 11 te s tim ony ?
12 A
The plan at this time is not finalized, but 13 our thinking is th at MHB will participa te in the SERA 14 testisony, and we are giving some thought to the need 15 f or pa rticipacion with the seismic structural peccle 's 16 tes tim ony, Christian Meyer and Jose Bosse tte.
17 There is also some possible testimony in the 18 area o f public interest.
19 2
With respect to pcssible participation in tha t 20 SEB A testimony, can you tell me how MHB would contribute 21 t6 tha t ?
22 A
It is not defined at this time.
In. general, a
N ALDERSON REPORTING COMPANY,INC.
r~
Minor deposition 51
(
1 A
It is, yes.
2 0
Do you know whether SER A has reached any 3
conclu sions in its analysis?
4 A
At this time, to the best of my knowledge they 5
have act.
They are still in the preliminary phases and,
6 even though the schedule has been extended sor.e wha t, it 7
.s still not long enough to have reached any conclusions 8
at thi s time.
It's going tc be right down to the wire, 9
- 7. m af raid.
10 0
Dc you knew yet what the extent of ycur 11 partiripation in SER A's testimony will be?
12 A
Not exac tly, no.
I know that I will be
(
13 involved in the preparation of it and will be workino 14 with them on a fairly regular basis until the 15 culmin ation of the testimony.
16 Q
Have you fed info rma tion to SER A?
17 A
I have been civing them informa tion, since th e 18 first day they were contacted, about what the 19 supplemental motion is, what the motions for summary 20 dispos ition are, and what information we have in the PRA 21 they may want to use, and that sort of thing.
We've 22 been repeating tha t constantly.
(_ '
ALDER 8oN REPORTING COMPANY,INC.
6
F Minor deposition 55 1
com ple ting the major goal, which was to have completed
(
2.
testim ony according to the schedule set f orth.
3 O
Why did they ever think it would be necessary 4-to loo k at something beyond the design basis events?
5 A
Well, to use another acronym, SARAs, severe 6
accide nt risk assessments, have been done on varicus 7
plants, and they tend to go well beyond design basis 8
events.
To the extent they were knowledgeable about 9
those having been done on o ther plants, they thought it 10 might be something that was being considered here, too.
11 Q
Do you know when SERA intends to have its 12 final opinions?
{
13 A
My goal is to make sure they have their final 14 opinio ns by testimony due date, and I think it's going 15 to be a tight schedule to m ake that.
16 0
Icu are aware, I take it, of Judge Miller's 17 order last Friday that all discovery responses, 18 includ ing deposition t estimony, be supplemented?
19 A
I have not seen that.
Somebody mentioned tha t 20 the re is a supplemental order.
I guess that's what 21 they're calling th e supplement.
22 2
It 's not in writing yet.
i ALDERSON REPORTING COMPANY lNC.
e Minor deposition 56 1
A That's a buzz name, but I have forgotten.
(
2 Q
Are you aware of the general requirement 3
that's been imposed?
4 A
Yes, I am aware that there is.
I thought th a t 5
was wi th regard to discovery, but I guess it's with 6
reg ard to discovery depositions, too.
I don't know wha t 7
the re quirements a re.
8 Q
You might find it fruitful to consult with 8
counsel about that and dete rmine wha t it is.
10 All right, you ssid that MHB has also given 11 though t to the need for its participation with respect 12 to th e seismic testimony.
I take it that would be the 13 testimony of Pro'fessor Meyer; is that ccrrect?
14 A
Meyer and Rossette, if Rossette ultimately 15 contributes there.
His schedule is a little hard tc tie 16 down.
17 Q
Do you know at this point whether Prof esser 18 Rossette will be a witness in this proceeding?
19 A
I personally am not convinced he is going to 20 be, bu t I think there is a high likelihood he vill be.
21 Q
When will that decision be made?
22 A
I don 't know.
Thats out of my hands.
L L
ALDeMoM MPORDNG COMPANY.lNC.
C F @ N.W_
r Minor depositiog7 C
1 2
Describe for me the extent to which MHB
(
2 intends to participate in the seismic testimony.
3 A
Well, as you may or may not be aware, their 4
effert is to analyze the equipment involved in the 5
onsite and off site configurations proposed by II1CC.
By 6
that I mean the TDI's and the alternatives, as we refer 7
to the m.
8 Their analysis will attempt to determine what 9
equipm e n t is likely to be impacted by an earthquake up 10 to
.2 g 's.
Once they make a seismic structural 11 determination as to what will be impacted, there is a 12 question which remains as tc what ultimate effect that 13 would have on the electrical supply reliability, and to 14 that extent I may be involved cr others at MHB, preh abl y 15 me, in helping supply that part of the testimony and 16 that assessment as to the impact on the elect'rical 17 supply.
18 Q
Do you know what the division of labor or 19 respon sibility is between Professors P. eyer and El R o s set te ?
21 A
Well, it's hard to define exactly, but 1
22 Christian Meyer is taking the lead in this effort.
Jos e km C
1 l
ALDERsoN REPORTING COMPANY,INC.
G F fR N.Wnw MFxAQQeas-esco
U:.
^
~
Minor deposition 59 C
A 1
County and there's been some ccrrespondence -- I dcn't
(
2 need to review that concerning whether Mr. Rossette 3
will b e a witness.
And again I request that, once that 4
decisi o n be mad e, thnt LILCC be advised a t the earliest 5
possible time, so he can be deposed.
6 And it will be LILCO's positicn, so there will 7
not be any surprises, that if he is not deposed before 8
the end cf disccvery, LILCO will oppose any testimony.
8 MR. BIRK ENHEIER:
Let me say, Suffolk Co un ty 10 has no t determined this yet, whether Dr. Rossette will 11 appear and have sponsored testimony in this proceeding.
12 That has not changed since the last time that 13 representation was made to you.
14 3Y MR. ROLFE:
(Resuming) 15 Q
Mr. Minor, do you know whether Professor Meye r 16 has re ached any conclusions yet?
17 A
My last conversations with Christian, which 18 date back several days now, but at that point he had 19 not.
20 Q
Has Prof essor Rossette reached any conclusions 21 of which you are aware?
22 A
Professor Rossette was making some general L
L ALDERSON REPORDNG COMPANY,INC.
\\
73 Minor deposition c
-1 opinio ns with respect to the seismic resistance or
(
2 capabilities of any of the ccmpenents cf LILCC's AC 3
power system as proposed for the lo w powe r testing ?
4 A
I don 't know how to answer your question, 5
becaus e it had som e double nega tives.
I do not progese 6
t o --
7 Q
Let me rephrase it.
Do you intend to expres:
8 any opinion with respect to the seismic resistance or 9
capabilities of any components of the AC power 10 com pon en ts?
11 A
I believe you are asking me if I will do 12 seismic analysis and nc, that is not my intent.
I
{
13 intend to use the seismic analysis done by otners and 14 impact the results of that.
15 0
I also believe you told me that a t ti.is time 16 you ar e not aw are o'f w h at the results in the seismic 17 analysis are?
18 A
I am.not, because I don 't believe there are 19 any.
20 Q
The third area you identified as being an arep 21 of possible participation by 'MHB is the public interer 7 Et area.
Can you describe f or me what HHB 's p a r tie. ica tion L
-,o
. o o e
,,,o.
r Minor deposition 96 4
1 probability of restoring power with the TDI diesels was 2
91.3 percent and the probability of restoring po wer in 3
the proposed low-power testing configuration was 91.1 4
percen t.
5 Does the county intend to evaluate those 6
result s in terms o f taking other than just a strictly 7
numerical comparison?
8 A
You're getting beyond the state of the 9
county 's testimony development at this point. I don't 10 think we have really formulated a position on something 11 like that.
12 0
Have you had any discussions or correspondence 13 recently with Mr. Ealey or Mr. Bagshi about their 14 consul ting work concerning the EMD diesels?
15 A
Yes, I've talked to them a couple of times, 16 largely trying to tie down schedules of availability, 17 tie down their involvement, and also to coordinate with 18 the ef forts leading to the site visit.
19 Q
When was the last time you had any 20 communications with them?
21 A
I had. a chance to talk to them when they were 22 in tow n.
The weeks are slipping by.
I don 't know how r
AtoensoN neronnNa COMPANY,lNC.
- n 7 sT, N.W W ASHINaTON, D.C. 20001 @2 83 9000 j
e-Minor deposition 97 1
long ago.
It' when they were deposed.
So that was
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2 last time.
3 J
Do you know whether they have reached any 4
conclu sions with respect to the EMD diesels?
5 A
I don 't believe th e y ' ve reached any firm 6
conclu sions at this time.
To my knowledge, they 7
h'av en ' t.
They may have, because it's been a week cr so 8
since I've talked to them, but I don't believe there are 8
any at this time.
10 0
Is PHB also coordinating the involvement of 11 Messrs. Eadden and Clermeyer in this low power 12 pro cee ding ?
(
13 A
No, we're not.
14 Q
Dc ycu have any knculedge of any opinions they 15 may in tend to express?
16 A
I ve done nothing more than shake their hands 17 when they were coming into Kirk pa trick, Lockhart the 18 other day, and I was leaving.
I have no idea what their 19 opinio ns are.
20 Q
Are there any other MH9 people who you foresee 21 might be witnesses in this low power proceedino, other 22 than yourself, Mr. Hubbard, or Mr. Bridenbaugh?
l ALDERSON r4EPORTING COMPANY,INC.
20 F ST, N.W, WASHINGTON, D.C. 20001 (200 828-8100
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