ML20093M961
| ML20093M961 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/29/1984 |
| From: | Farley E HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20093M965 | List: |
| References | |
| CON-#484-803 0L, L, NUDOCS 8410310122 | |
| Download: ML20093M961 (6) | |
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ELATED CCREEY fE0
'84 po.,30 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f,0:45 Before the Atomic Safety and Licensina Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322(OL)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S MOTION TO ADMIT SUPPLEMENTAL TESTIMONY ON SUFFOLK COUNTY CONTENTION REGARDING CYLINDER BLOCKS Long Island Lighting Company (Lilco), for good cause, moves the Board for leave to file the attached Supplemental Testimony and in support of such Motion states:
(1) Li,1co's Supplemental Testimony on cylinder blocks is limited to a discussion of new information on cam gallery indications in the EDGs.
Tnis Supplemental Testimony is 4
necessary to apprise the Board, the NRC S*.aff and the other parties of relevant and material evidence recently obtained as a result of the endurance test run currently being conducted by Lilco on the EDG 103.
(2) In summary, the Supplemental Testimony advises the parties that depth gage measurements of the indications in the i
replacement EDG 103 block have demonstrated that the indications are shallow surface imperfections.
The deepest indication was measured to have a depth of.014 inch.
- Second, the testimony reports that strain gage testing on the 8410310122 841029
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U e{d PDR ADOCK 05000322 9so3 x
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. replacement EDG 103 block, which is also applicable to the EDG 101 and EDG 102, demonstrates that the vertical stresses in the can gallery area are compressive, thus preventing any crack propagation, i
(3) This Supplemental Testimony could not have been filed before today.
Although Lilco received some preliminary cam gallery strain gage data on October 10, which was produced to the County and Staff at the deposition of Drs. Rau and Wachob on October 11, the vertical stress results from the strain gages were not available until October 27:
4 (4) This testimony will not prejudice the County or the Staff.
The fact that strain gage tests would be performed in response to requests by the NRC Staff was disclosed to the County on Tuesday, October 2, and the County's counsel and eenaultants saw the placement of some of the gages on October 3.
The earliest preliminary cam gallery strain gage data was made available to the NRC Staff and the County at the deposition of Drs. Rau and Wachob, and the County in fact examined FaAA on the preliminary data and attached it to the deposition as Exhibit 3.
Similarly, the County examined FaAA concerning whether depth yage measurements would be made of the indications in the replacement EDG 103 block.
These depth gage inspection reports were provided to the County and the Staff on i.-
October 21, which was the day after Lilco's counsel received I
the reports.
I
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- (5) The relevance and materiality of the information contained in Lilco's Supplemental Testimony is demonstrated by
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the fact that_both the County and the Staff discuss the indications found in the replacement EDG 103 block in their testimony.
Further, the Staff testimony actually addresses the desirability of obtaining strain gage measurements of the stresses.in the cam gallery area.
(6) The Supplemental Testimony is necessary to make the record fully and accurately reflect existing facts which have recently been'obtained.
Unless the record includes the facts regarding the depths of the indications in the replacement EDG 103 cam gallery, and the data on the actual state of stress in the cam gallery of the EDGs, there cannot be a full, complete and meaningful adjudication of the cylinder block contentions.
WHEREFORE, Lilco respectfully requests that the Board admit Lilco's Supplemental Testimony on cylinder blocks.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
'O AbHY By E.MiltonFarle,y]III*
Hunton & Williams P. O. Box 19230 2000 Pennsylvania Avenue, N.W.
Washington, D.C.
20036
. W. Taylor Reveley, III Robert M. Rolfe Anthony F. Earley, Jr.-
Darla B. Tarletz Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 Odes L. Stroupe, Jr.
David Dreifus Hunton & Williams BB&T Building P. O. Box 109 Raleigh, North Carolina 27602 e.
DATED:
October 29, 1984
'b a,.
. CERTIFICATE OF SERVICE in the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322'(OL)
-1 hereby certify that copies of LILCO's Motion to Admit Supplemental Testimony on Suffolk County Contention Regarding Cylinder Blocks were served this date upon the following by first-class mail, postage prepaid, or by hand 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 4350-East-West Highway Appeal Board Panel Fourth Floor (North Tower)
U.S. Nuclear Regulatory Bethesda, Maryland 20814
-Commission Washington, D.C.
20555 Dr. Peter.A. Morris
- Administrative Judge
. Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission
-Washington, D.C.
20555 4350 East-West Highway.
Fourth Floor (North Tower)
Robert E. Smith, Esq.
Bethesda, Maryland 20814 Guggenheimer & Untermyer 80 Pine Street Dr. George A. Ferguson*
New York, New York 10005 Administrative Judge School of Engineering Herbert H. Brown, Esq.*
Howard University Lawrence Coe Lanpher, Esq.
Room 1114 Alan R. Dynner, Esq.
2300 - 6th Street, N.W.
Joseph J. Brigati, Esq.
Washington, D.C.
20059 Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
8th Floor Washington, D.C.
20036
a g
~ Bernard M. Bordenick, Esq.*
Stephen B. Latham, Esq.
David A. Repka, Esq.
Twomey, Latham & Shea Richard J. Goddard, Esq.
33 West Second Street U.S. Nuclear Regulatory Post Office Box 398 Commission-Riverhead, New York 11901 Maryland National Bank Bldg.
7735 Old Georgetown Road Ralph Shapiro,.Esq.
Bethesda, Maryland 20814 Cammer and Shapiro, P.C.
9 East 40th Street Martin Bradley Ashare, Esq.
New York, New York 10016 Attn: Patricia A. Dempsey, Esq.
County Attorney James Dougherty, Esq.
Suffolk County Department 3045 Porter Street of Law Washington, D.C.
20008 Veterans Memorial Highway Hauppauge, New York 11787 Jonathan D.
Feinberg, Esq.
New York State Mr., Marc W. Goldsmith Department of Public Service Energy Research Group Three Empire State Plaza 4001 Totten Pond Road Albany, New York 12223 Waltham, Massachusetts 02154 Howard L. Blau MHB Technical Associates 217 Newbridge Road 1723 Hamilton Avenue Hicksville, New York 11801 Suite K San Jose, California 95125 Fabian G. Palomino, Esq.
Special Counsel to the Mr. Jay Dunkleberger Governor New York State Energy Office Executive Chamber, Room 229 Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 lb77 A1/w 7f E. Milton Fa dy, 'I I(F Hunton & Williams 2000 Pennsylvania Avenue, N.W.
Suite 9000 Post Office Box 19230 Washington, D.C.
20036 DATED:
October 29, 1984 f-i
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